Mary T. King and Fatai O. King - Page 19




                                        - 19 -                                          
             T.C. Memo. 1991-385.  We find that the bank statements                     
             substantiate petitioner’s testimony regarding the charges                  
             in the aggregate amount of $233.10 that are labeled as                     
             “analysis charges”.                                                        
                 Petitioners also claim a deduction in the amount of                   
             $936 for lottery service charges.  Respondent concedes the                 
             deductibility of that amount.                                              
                  Petitioners claim a deduction for payments to the                     
             Pennsylvania Lottery in the amount of $10,561.  In support                 
             thereof, they introduced a check drawn by petitioner to the                
             order of “cash” in the amount of $2,200 and a check drawn                  
             by petitioner to his own order in the amount of $8,361.15.                 
             They also introduced the copy of a cashier’s check that                    
             appears to be drawn to the order of the Pennsylvania                       
             Lottery in the amount of $8,361.15.  Petitioner testified:                 
             “The Pa Lottery, I owe them $10,562 because I lost the                     
             tickets.”  Petitioners introduced no invoices or                           
             correspondence from the Pennsylvania Lottery regarding                     
             these alleged payments, and they did not deduct these                      
             payments on their original return.  Petitioner’s testimony                 
             concerning the nature of these payments is vague, confus-                  
             ing, and unbelievable.  We find that petitioners have not                  
             substantiated their eligibility to deduct these payments.                  








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