- 32 - 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 However, petitioners have offered no explanation of the additional $800 withdrawn from H&B's account, and there is no basis in the record on which we can reject respondent's determination that this additional $800 constitutes income to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 containsPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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