Raymond F. Kling and Barbara K. Kling - Page 38




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          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.                                              










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