Raymond F. Kling and Barbara K. Kling - Page 40




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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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