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argument and sustain respondent's determination that all
of H&B's payments toward the purchase of the Lincoln Mark
VII, and its payments for insurance, tires, and other
expenses related to the automobile, constitute income to
petitioners.
Converted Payments From Trans State Pavers
During 1988, petitioner signed four checks drawn on
H&B's First Interstate account and made payable to First
Interstate in the total amount of $18,033.42. The proceeds
of these checks were used to purchase cashier's checks
totaling $18,026.42, each of which was payable to Jordan
Distributors. Also in 1988, petitioner signed three checks
drawn on H&B's First Interstate account and made payable to
cash in the total amount of $17,950. The proceeds of these
checks were also used to purchase cashier's checks payable
to Jordan Distributors.
The above cashier's checks were used to purchase fuel
from Jordan Distributors for delivery and sale to Trans
State. There is no evidence that petitioner ever deposited
the funds he received from Trans State into any of H&B's
bank accounts or otherwise paid the funds to H&B.
Respondent determined that petitioner converted the money
he received from Trans State to his own personal use.
Respondent determined that the amount of money so
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