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During 1991, petitioners made car insurance payments and
purchased clothes for two of their children, Jacqueline and
Johnathan, for which they were reimbursed. Petitioners provided
canceled checks to corroborate their testimony regarding these
reimbursements. The amounts represented by these reimbursements
in the deposits, therefore, are not subject to tax.2 On the
basis of the record, we are persuaded that for 1991, Jacqueline
and Johnathan reimbursed petitioners $1,000 and $700,
respectively, for car insurance and $200 each for clothes.
During 1991, petitioners took various trips with certain
other individuals. Petitioners sometimes would charge the entire
cost of the trip on their credit card, and the other individuals
would then reimburse them for their share of the cost.
Petitioners testified credibly regarding the reimbursements for
these trips and provided credit card statements for
corroboration. Patricia Hurst, a travel companion, also
testified credibly regarding reimbursements made to petitioners
for certain trips. Accordingly, the amounts represented by these
reimbursements in the deposits, described more fully below, are
not subject to tax.
2 The reimbursements from Jacqueline and Johnathan for
1991 were a combination of checks and cash. Petitioners and
respondent agree that the checks payable to Jacqueline and
Johnathan that were deposited into petitioners' account in 1991
are nontaxable. The difference between our determination of the
total reimbursement from the children and the agreed-upon amounts
in the form of checks is the resulting cash reimbursement.
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