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lottery tickets to lottery headquarters for verification. Once a
ticket has been verified, either the money is wired to the
retailer's lottery account to pay the winning ticket or the
Pennsylvania State lottery writes a check directly to the winner.
During 1994, Mr. King made a $9,540 cash deposit into his
lottery account with PNC Bank (PNC), and he subsequently learned
that his account was not credited with the deposit. As a result,
Mr. King hired an attorney and filed a complaint in 1994 against
PNC to recover the $9,540 missing deposit.3 On June 27, 1995, a
panel of arbitrators found in favor of Mr. King. Shortly
thereafter, PNC appealed the arbitration award. On March 12,
1996, the Common Pleas Court of Philadelphia, Pennsylvania, ruled
in favor of Mr. King and ordered PNC to reimburse him. As a
result, Mr. King was reimbursed in 1996.
During 1994, petitioners owned a Hyundai automobile. Mr.
King used the Hyundai to commute to work daily.
During 1993, Mr. King sold a newsstand located at 139 North
West Corner of Chelten Avenue in Philadelphia, Pennsylvania, for
$40,000. Under the terms of the sales agreement, Mr. King
received a $5,000 deposit in 1993 and monthly payments of $972.22
with zero percent interest for 36 months. As a result, Mr. King
received 12 monthly installment payments of $972.22 each for a
3Because of a typographical error in the stipulation,
"$9,450" should be "$9,540."
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