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a separate check to purchase insurance for the Lincoln Mark
VII on January 17, 1989. Thus, the entire amount of the
cashier's check is not income to petitioners. However,
petitioners have offered no explanation of the additional
$800 withdrawn from H&B's account, and there is no basis
in the record on which we can reject respondent's
determination that this additional $800 constitutes income
to petitioners. Accordingly, we find that $800 of the
proceeds of check No. 1477 constitutes income to
petitioners.
On November 4, 1988, petitioner signed check No. 1346
drawn on H&B's First Interstate account and made payable to
cash in the amount of $1,500. Petitioner used the proceeds
of this check to purchase a cashier's check. However,
petitioners have provided no explanation of how the
proceeds of this cashier's check were used. Consequently,
petitioners have failed to satisfy their burden of proving
that the proceeds of check No. 1346 do not constitute
income to them, as determined by respondent.
During 1988, petitioner signed 17 additional checks
drawn on H&B's First Interstate account and made payable to
cash in the aggregate amount of $11,086.84. Some of these
checks bear notations stating the purposes for which they
were drawn. H&B's pegboard ledger sheet also contains
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