Raymond F. Kling and Barbara K. Kling - Page 37




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          $933.78.  Jennifer did not testify at trial in this case.                   
          Although Barbara testified, she did not address the sale of                 
          Jennifer's collection or even confirm that Jennifer ever had such           
          a collection.  Petitioners did not ask Morova about the sale when           
          he testified at trial.  Petitioners have not established that the           
          check to Jennifer was a distribution of proceeds from the sale of           
          her collection or that the $933.78 payment is otherwise                     
          deductible in 1991.                                                         
          i.  Wade Carsel                                                             
               Wade Carsel is a dealer whose company is named Box Man.                
          Petitioners have not provided any evidence regarding the $100               
          check paid to Mr. Carsel.  Therefore, petitioners' income is not            
          reduced by $100.                                                            
          j.  Carl Dietz                                                              
               The $19,775 check paid to Dietz is the money from the                  
          Megacards deal that Raymond distributed to Dietz.  The sale was             
          made in 1991, and the proceeds from the sale were deposited into            
          the Ameritrust account.  Therefore, petitioners' income for 1991            
          will be reduced by $19,775.                                                 
          k.  Cash                                                                    
               Dave Cirino (Cirino) is a dealer who bought large wax boxes,           
          sorted out the stars, and then sold the commons.6  The checks               
          payable to cash in the amounts of $1,200 and $120 are for commons           

               6The term "commons" refers to baseball card that feature a             
          player who is not considered a star.                                        




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