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m. Thomas J. Bowers
The $1,260 check written to Thomas J. Bowers is for Desert
Storm sets. We find that the purchase of $1,260 worth of Desert
Storm sets more likely than not was a bulk purchase for the
buyers group, rather than for Raymond's private collection.
Therefore, the deduction for purchases for 1991 is increased by
$1,260.
n. Bob Kelly
Bob Kelly was paid $164 for wax. We find that the $164
purchase of wax 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 wax was sold during
1991 or 1992. Therefore, the cost of goods sold is not increased
by the cost of the cards.
o. Jim Wilson
Jim Wilson owns or works for a vending machine company.
Raymond purchased a $200 used video football game from Mr. Wilson
for Morova's store. Morova never paid Raymond for the game.
Raymond and Morova initially intended to operate the store as a
partnership to which Raymond agreed to contribute video games.
The purchase of the game was not related to the bulk purchases
for the buyers group. Petitioners have failed to show that the
cost of the video game is deductible in 1991 or 1992.
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