- 38 - purchased from Cirino. We find that the $1,200 purchase of the commons more likely than not was a bulk purchase for the buyers group, rather than for Raymond's private collection. Therefore, the purchases for 1991 is increased by $1,200. We cannot say, however, that the $120 purchase of the commons was more likely than not a purchase for the buyers group, rather than for Raymond's private collection. Petitioners have not shown that the commons purchased for $120 from Cirino were sold and the proceeds from that sale were deposited into their accounts during 1991 or 1992. Therefore, petitioners have not established that they are entitled to deduct the $120 in either 1991 or 1992. l. John Pepera John Pepera (Pepera) is a district manager for a newspaper called the Cleveland Plain Dealer. The $375 check paid to Pepera was for the purchase of a large number of newspapers for a special event relating to sports. We find that the purchase of the newspapers 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 newspapers were sold, and that the proceeds were deposited into their accounts during 1991 or 1992. Therefore, the income for neither year is reduced by the cost of the newspapers.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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