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on the Ameritrust account. Respondent allowed a deduction for
purchases in 1991 for the $3,156 check and the $5,270 wire
transfer.
Raymond claims that on February 4, 1991, he transferred by
wire $8,253.96 to Unique Vinyl from the Ameritrust account to pay
for binders for the buyers group. Although the bank records show
that a check in the amount of $8,253.96 was paid on February 4,
1991, petitioners did not provide any evidence establishing that
Unique Vinyl was the payee of the check or that the payment was a
wire transfer to Unique Vinyl. Petitioners did not provide a
receipt, invoice, or otherwise establish that the payment
represents a deductible expense.
4. Charge on Ameritrust Account
Jim Beckett publishes the Beckett Price Guides for baseball
cards, basketball cards, hockey cards, and nonsport cards. He
publishes an annual guide that sells for $20 and monthly updates
that sell for $1. Raymond purchased large quantities of the
price guides.
Respondent allowed a deduction in 1991 for checks made
payable to Beckett or the buyers group totaling $4,166. Two of
the checks, one dated April 5, 1991, and the other dated June 7,
1991, were each in the amount of $996. On February 20, 1991, the
Ameritrust account was charged $996. Respondent did not allow a
deduction for the $996 charge. Petitioners claim that the
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