Raymond F. Kling and Barbara K. Kling - Page 32




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                             National City Bank Account                               
                    Payee                            Amount                           
                    Bob Kelly                     $164.00                             
                    Jim Wilson                    200.00                              
                    Evelyn Johanson               1,614.00                            
                    Wholesale Club                3,000.00                            
                    Sam's Club                    1,874.15                            
                    Cash                     1,600.00                                 
               The following discussion relates to the items listed above             
          that were withdrawn from the Ameritrust and National City Bank              
          accounts in 1991.                                                           
          a.  Raymond                                                                 
               A check dated May 30, 1991, written on the Ameritrust                  
          account is made payable to Raymond in the amount of $3,173.  "E&J           
          Sales" is written on the memo section of the check.  The record             
          also shows that a check from E&J Sales made payable to Raymond              
          was deposited into the Ameritrust account on May 30, 1991.                  
          Petitioners assert that cost of goods sold in 1991 should be                
          increased to reflect the purchase of the goods for E&J Sales.               
               Raymond explains the check as follows:  E&J Sales is a                 
          company that sells wholesale; E&J Sales asked Raymond to purchase           
          some merchandise for the company in California and delivered a              
          check in the amount of $3,173 made payable to Raymond; Raymond              
          knew the California company would not accept a third party check;           
          therefore, he deposited the check from E&J Sales into the                   
          Ameritrust account and wrote a check to himself in the same                 
          amount to pay for the merchandise.                                          






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