Raymond F. Kling and Barbara K. Kling - Page 41




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          that indicates that the money was used to purchase baseball                 
          cards.  Petitioners have not established that it is more likely             
          than not that these checks were used to purchase baseball cards             
          for the buyers group, rather than for their personal living                 
          expenses.  Therefore, petitioners have failed to establish that             
          they are entitled to a deduction for the payments.                          
          r.  Cash                                                                    
               Barbara signed and endorsed a check drawn on the National              
          City Bank account dated March 18, 1991, payable to cash in the              
          amount of $1,600.  She then gave the cash to Raymond.  Raymond              
          claims the $1,600 was used to purchase cards from a company that            
          would only accept cash, because the buyers group had bounced some           
          checks.  There is no notation on the check or any other evidence            
          in the record to indicate its purpose.  Petitioners have not                
          established that it is more likely than not that cash was used to           
          purchase supplies for the buyers group, rather than for their               
          personal living expenses.  Therefore, petitioners have failed to            
          establish that they are entitled to a deduction for the $1,600.             
          3.  Unique Vinyl Transaction                                                
               Unique Vinyl makes binders.  On March 13, 1991, Raymond wire           
          transferred $5,270 from the National City Bank account to Unique            
          Vinyl's bank account for purchases made during 1991.  The bank              
          charged a fee of $13.75 for the wire transfer.  Also during 1991,           
          a $3,156 check made payable to Unique Vinyl was written and paid            







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