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purchase for the buyers group. Therefore, the cost of goods sold
for 1992 should be increased by $1,035.
e. Bill Clay
Bill Clay owned Clay's Collectibles and manufactured
baseball card boxes. We find that the $1,228 check written to
Bill Clay more likely than not was a purchase for the buyers
group. Therefore, the cost of goods sold for 1992 should be
increased by $1,228.
f. Raymond
The $5,000 check to Raymond was a portion of his $18,000
profit from a picture deal that he reported on petitioner's 1991
return. Since the $5,000 was reported on the return,
petitioners' omitted income is reduced by $5,000.
g. Cash
Three checks totaling $3,400 were made payable to cash. One
check in the amount of $1,000 indicates that it was for Jim
Mitchell of Ontario Hobby Dealers Supply of Canada. Another
check in the amount of $1,600 indicates that it was for Ohio
Coin. Respondent allowed deductions for other checks written to
those payees. We find that these checks more likely than not
were purchases for the buyers group. Therefore, the cost of
goods sold for 1992 should be increased by $2,600.
The third check in the amount of $800 was for the purchase
of pinball machines for Morova's store. The purchase was not
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