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income as determined by respondent for 1991 should be reduced by
the amounts of these checks.
b. Bob Kelly
Bob Kelly is a small card dealer. The $500 check paid to
Mr. Kelly was for the purchase of cards. We find that the
purchase of the $500 of cards was more likely than not a purchase
for Raymond's private collection, rather than a bulk purchase for
the buyers group. Petitioners have not shown that the cards
purchased were sold during 1991 or 1992. Therefore, petitioners'
income is not reduced by $500.
c. Ray Duffy
Ray Duffy is an autograph promoter. The $150 check paid to
Mr. Duffy was for the purchase of autographed pictures. We find
that the purchase of the autographed pictures more likely than
not was a purchase for Raymond's private collection, rather than
a bulk purchase for the buyers group. Petitioners have not shown
that the autographed pictures purchased from Mr. Duffy were sold,
and that the proceeds from that sale were deposited into their
accounts during 1991 or 1992. Therefore, petitioners' income for
1991 or 1992 is not reduced by $150.
d. O.U.P.A.
Raymond claims that the $300 check written to the Ohio Union
of Patrolman's Association was for an advertisement placed in the
police association's yearly fund raiser book for Davey's Cards.
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