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p. Evelyn Johanson
Evelyn Johanson is the wife of a former security guard who
worked at Cleveland Stadium. Raymond wrote a check for $1,614 to
Mrs. Johanson for her husband's collection of autographed
baseballs. Raymond claims that he purchased the baseballs for
Dietz, that the baseballs went to Dietz's store Sports of Sorts,
and that Raymond was repaid the $1,614 when they settled the
Megacards deal. Raymond did not call Dietz or Mrs. Johanson as a
witness, and there is no other evidence to establish that the
check was for the purchase of baseballs or that the baseballs
went to Dietz. Therefore, petitioners have failed to establish
that the $1,614 is deductible in 1991 or 1992.
q. Wholesale Club/Sam's Club
Wholesale Club (later became Sam's Club) distributed
baseball cards. Wholesale Club was able to obtain newly issued
baseball cards 2 to 3 weeks before the tobacco and candy
distributors. Raymond claims that the $3,000 check payable to
Wholesale Club, the $1,874.15 check payable to Sam's Club, and
the $2,500 check payable to cash (with "Sam's Club" written on
the memo portion of the check) were for cases of new baseball
cards. Some of the checks in the record indicate the purpose of
the check, e.g., some checks have "commons" written on the memo
section of the check. Unlike those checks, there is nothing
noted on the checks written to Wholesale Club or to Sam's Club
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