Raymond F. Kling and Barbara K. Kling - Page 30




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               Respondent did not explain the basis or standard used to               
          determine whether a given item would be included in the purchases           
          for which a deduction was allowed in 1991 or 1992.  The agent did           
          not attempt to account for beginning and ending year inventories.           
          It appears to the Court, however, that the agent, having                    
          confirmed that the goods acquired for the buyers group were                 
          distributed to the members at cost, allowed a deduction for items           
          identified as purchases made for the buyers group.  Consistent              
          with that determination, we shall allow a deduction for purchases           
          made for the buyers group.  Additionally, we shall allow a                  
          deduction for payments unrelated to the buyers group but                    
          attributable to sales or transactions completed during the                  
          taxable year at issue.                                                      
          1.  Klein News                                                              
               Klein News is a distributor of magazines.  In 1990, Raymond            
          agreed to provide metal racks to hold plastic pages, sleeves, and           
          hard plastic for sports cards for Klein News.  Klein News agreed            
          to purchase between $20,000 and $25,000 worth of merchandise per            
          month.  On December 26, 1990, Raymond wrote a check in the amount           
          of $24,048.85 made payable to Ohio Coin for payment of                      
          merchandise bought from Ohio Coin related to the deal with Klein            
          News.  In 1991, Raymond sold merchandise to Klein News for                  
          $23,987.46, the payment for which was deposited into the                    
          Ameritrust account on February 1, 1991.                                     







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