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In August 1992, petitioner took out a $1,000 cash advance on
his credit card. Petitioner provided a credit card statement for
corroboration. The amount represented by this cash advance in
the 1992 deposits is nontaxable.
Petitioner received loans from his mother during 1992.
Petitioner provided a canceled check from his mother of $300.
Petitioner's mother also testified credibly regarding cash loans
of $500 and $300. The amounts of these loans are not subject to
tax.
Petitioners claim that certain amounts of the 1992 deposits
are from the nontaxable cash hoard source. On the basis of the
entire record, including the fact that both petitioners worked
during the year, we find $2,500 to be a reasonable appraisal of
deposits from the nontaxable cash hoard.
In sum, we find that $6,700 of the 1992 bank deposits is
nontaxable and must be removed from the unreported income
determined by respondent.
Issue 2. Dependency Exemption
Respondent determined that petitioners were not entitled to
a claimed dependency exemption deduction for their daughter,
Jacqueline, for 1992. The reason stated for the disallowance was
that petitioners did not establish that they had provided more
3(...continued)
total reimbursement from the children and the agreed upon amounts
in the form of checks is the resulting cash reimbursement.
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