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they had accumulated by the end of 1986 from the sale of most of
their Brazilian assets and inheritances they received in 1986.
We find that, of the disputed deposits, $66,597.25 in 1990 and
$194,913 in 1991 came from petitioners' funds in Brazil and from
other nontaxable sources, such as transfers between accounts,
cashing checks or exchanging money for friends, the PanAm refund,
and a manufacturer's rebate. Petitioners have not shown that the
source of the funds for the remaining items in dispute was
nontaxable. We conclude that petitioners had income from
International of $64,911 for 1990 and $201,992 for 1991.
C. Net Operating Loss Carrybacks
Petitioners contend that they had losses of $15,976 in 1990
and $15,491 in 1991 which they may carry back to 1987 and 1988.
Section 172 allows a taxpayer to deduct net operating
losses. Petitioners bear the burden of proving that they had net
operating losses in 1990 and 1991. Rule 142(a); United States v.
Olympic Radio & Television, Inc., 349 U.S. 232, 235 (1955).
Petitioners must prove the amount of the net operating loss
carryback. Sec. 172(c); Jones v. Commissioner, 25 T.C. 1100,
1104 (1956), revd. and remanded on other grounds 259 F.2d 300
(5th Cir. 1958); Vaughan v. Commissioner, 15 B.T.A. 596, 600
(1929). Petitioners did not report income of $89,556 in 1990 and
$143,588 in 1991. Petitioners did not show that they had net
operating losses for 1990 and 1991 after taking into account the
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