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G. Sales From Raymond's Private Collection
1. James Amodio
James Amodio purchased sports memorabilia and other
collectibles from Raymond during the years at issue. Two checks
signed by James Amodio made payable to Raymond in the amounts of
$145 and $152.75 were deposited into the Ameritrust account on
May 20, 1991, and December 6, 1991, respectively.
2. John Cadier
In 1991, Raymond sold a baseball card to John Cadier for
$200. The purchase price was deposited into the Ameritrust
account.
3. Robert Koehler
In 1991, Raymond sold baseball photos to Robert Koehler for
$400. The purchase price was deposited into the Ameritrust
account.
4. Thomas Jurcak
In 1991, Raymond sold a baseball to Thomas Jurcak for $48.
The $48 was deposited into the Ameritrust account.
H. Petitioners' 1991 and 1992 Federal Income Tax Returns
Petitioners filed their joint Federal income tax returns for
the taxable years 1991 and 1992. On their 1991 return,
petitioners reported total income of $18,000. On Schedule D,
Capital Gains and Losses, of the 1991 return, petitioners
reported gain from two sales of photos. They reported $5,000
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