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E. License Use
Petitioners assert that $39,163 of their unexplained
deposits for 1992 is attributable to salesmen's use of Mr. Ortiz'
license to purchase automobiles. They argue that only money
attributable to the $100 fees that Mr. Ortiz charged the salesmen
for each car purchased using this license should be taxed.
However, petitioners failed to substantiate any of these
salesmen's purchases and provided no information indicating how
many $100 fees they received. Petitioners also failed to show
that money received from any such transactions was deposited into
either of the bank accounts.
F. Conclusions as to Unreported Income
In sum, we hold that Mr. Ortiz had unreported self-
employment income from his wholesale used car business of $17,390
in 1991 and $49,163 in 1992. Petitioners had unreported interest
income of $18,000 in 1991 and $4,000 in 1992.
Issue 2. Additional Interest Income
We hold that petitioners did not receive additional interest
income of $3,500 in 1991 and $3,000 in 1992. These amounts are
included in the interest payments petitioners have conceded they
received from Mr. Rodriguez. See supra Issue 1D.
Issue 3. Capital Loss for 1991
Under section 1211 a taxpayer other than a corporation is
limited to $3,000 in net capital losses in any given tax year.
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