Raymond F. Kling and Barbara K. Kling - Page 45




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          should be reduced by the $750.  Additionally, petitioners are not           
          entitled to a deduction for repayment of the loan.                          
          b.  C.C.P.L.                                                                
               The $836 check to CCPL was for a shelving unit purchased at            
          an auction by the Cuyahoga County Public Library for Morova's               
          store.  The purchase was not part of the bulk buying for the                
          buyers group.  Petitioners have failed to establish that the cost           
          of the shelving unit is otherwise deductible in 1992.                       
          c.  John Banville                                                           
               John Banville works for the National Football League.  The             
          $600 check payable to John Banville is for the purchase of                  
          footballs and commemorative footballs from the Super Bowl.  We              
          find that the purchase of the footballs more likely than not was            
          a purchase for Raymond's private collection, rather than a bulk             
          purchase for the buyers group.  Petitioners have not shown that             
          the footballs were sold and that the proceeds were deposited into           
          their accounts during 1991 or 1992.  Therefore, petitioner's                
          income for either year is not reduced by the cost of the                    
          footballs.                                                                  
          d.  Eric Lawrence                                                           
               Eric Lawrence owns Lawrence Machines, a company that makes             
          plastic sheets.  Respondent included other payments to Lawrence             
          Machines in the amount of purchases.   We find that the $1,035              
          check written to Eric Lawrence more likely than not was a                   







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