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6. Additional Checks Written in 1992 on the Ameritrust/Star Bank
Account
Petitioners claim that the deductions for purchases and
expenses should be increased for the following amounts paid from
the Ameritrust/Star Bank account in 1992:
Payee Amount
Barbara Kling $750
CCPL1 836
John Banville 600
Eric Lawrence 1,035
Bill Clay 1,228
Raymond 5,000
Cash 3,400
1Cuyahoga County Public Library.
2Repair of vehicle Raymond purchased from Cumba Motors in
1991.
The following discussion relates to the items listed above
that were withdrawn from the Ameritrust and National City Bank
accounts in 1991
a. Barbara
The $750 check written to Barbara was to repay her mother
for a $750 loan that she made to Raymond. Petitioners argue that
their income should be reduced to reflect the loan. Petitioners,
however, have failed to show that the $750 Barbara's mother lent
them was deposited into either the Ameritrust or National City
account. There is no evidence that the $750 was included in
respondent's determination of gross receipts. Petitioners have
failed to establish that the gross receipts
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