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converted, as measured by the amount of H&B's funds used
to purchase the fuel, constitutes taxable income to
petitioners.
Petitioners have failed to present any documentary
evidence that petitioner paid the money he received from
Trans State to H&B. Although there appear to have been
some unexplained deposits into H&B's First Interstate
account during the years at issue, petitioners have failed
to prove that the money petitioner received from Trans
State was deposited into the account. It is also clear
that the source of funds used to purchase each of the
cashier's checks made payable to Jordan Distributors
consisted of checks drawn on H&B's First Interstate
account. Thus, we are unable to find that petitioner used
the money he received from Trans State to pay Jordan
Distributors for the fuel H&B transported between the two.
We note Ms. MacKall's testimony that petitioner either
cashed the checks he received from Trans State and used the
proceeds to purchase cashier's checks, or deposited cash
received from Trans State into H&B's First Interstate
account and then issued separate checks to purchase
cashier's checks. However, we do not credit Ms. MacKall's
vague testimony on this point. Moreover, there are no
notations on the pegboard ledger evidencing deposits
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