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sible to prove the identity of the payors during the years at
issue of certain items that were deposited into petitioner’s
accounts. That is because, according to petitioner, the docu-
ments that showed those payors are voluminous and could not have
been conveniently examined by the Court. We disagree.
Only 51 of the entries in respondent’s workpapers relate to
deposits that petitioner contends remain at issue in this case.
Respondent objects to only 26 of those entries. See supra note
14. Respondent does not object to the remaining 25 entries
because the payors listed in those entries are established by
other evidence in the record without regard to the entries in
respondent’s workpapers. Of the 26 material entries that are the
subject of respondent’s evidentiary objection, only 25 actually
list payors.17 It appears that, instead of relying on those 25
material entries that are the subject of respondent’s evidentiary
objection, petitioner could have established the identity of the
payors listed in those 25 entries by offering into evidence the
originals or the duplicates of 24 checks and 1 money order. We
believe that we could have conveniently examined at the further
trial the originals or the duplicates of those 24 checks and 1
money order. In the instant case, we do not believe, and in any
event petitioner has failed to show, that those originals or
17One material entry that is the subject of respondent’s
evidentiary objection does not show the payor of the deposit
relating to that entry. Instead of the name of the payor, the
words “Unable to locate” appear with respect to a deposit of
$20,119 made into petitioner’s equity line account on Mar. 19,
1991.
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