- 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.
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