Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 34

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               Petitioners argue that many of these deposits came from                
          their wages, which were reported on their individual income tax             
          return.  However, they have offered no proof of this beyond                 
          vague, unsubstantiated testimony.  Additionally, respondent's               
          revenue agent backed out net income that was reported on                    
          petitioners' return when she performed her bank deposits                    
               Michoff, Jr., contends that a $3,000 deposit which is in               
          issue came from the sale of a Porsche to Bill McKay.  Michoff,              
          Jr., contends that he purchased the Porsche for $2,000 and put              
          $1,000 worth of repairs into the car.  Other than his own                   
          testimony, which we find lacking in credibility, Michoff, Jr.,              
          presented three exhibits as proof of his purchase price and cost            
          of repairs; these exhibits lack any probative value as well as              
          any indicia of trustworthiness.10                                           

               10  As proof of his purchase price Michoff, Jr., submitted             
          two exhibits to the Court.  First, Michoff, Jr., submitted a                
          document from the State Board of Equalization Occasional Sales              
          Use Tax Unit.  This document is a letter which states that                  
          Michoff, Jr.'s, Certificate of Purchase Price, indicating his               
          purchase price of the car, was selected for routine verification            
          and that he would need to submit other evidence providing                   
          verification of value.  This document proves nothing as it is               
          merely a request for information.  Second, Michoff, Jr.,                    
          submitted a bill of sale purportedly showing that he purchased a            
          Porsche for $2,000.  However, this bill of sale lacks a Vehicle             
          Identification Number, a transfer date, and the address of the              
          seller.  There is no indication that this is an actual bill of              
               As proof of the cost of repairs, Michoff, Jr., submitted a             
          pile of receipts.  These receipts do not show for what car the              
          parts were ordered or the work done.  Additionally, Michoff, Jr.,           
          included receipts dated as late as May 28, 1991, for a car which            

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