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transaction with Mr. M., and respondent’s determination is not
sustained.14
Respondent determined that petitioner had unreported income
of $110 in 1989 from the sale of tickets and tapes to an
individual named Paul H. In September of 1989, Paul H. wrote a
check to Real Services in the amount of $110, in payment for
prerecorded music tapes. Petitioner deposited this check into
Real Services’ checking account. Respondent concedes that
petitioner is entitled to a cost-of-goods-sold allowance of $12
with respect to these tapes. We accordingly find that petitioner
had unreported income of $98 in 1989 from this transaction and
sustain respondent’s determination to that extent.
B. 1990 Sales of Electronics and Rental Income
Respondent determined that petitioner had unreported income
of $3,000 in 1990 from the sale of additional electronic
equipment to Ted and Brian P. Brian P. confirmed this amount at
trial. From numerous receipts, petitioner has identified the
items that she purchased and resold to Ted and Brian P. The
receipts indicate that her cost for this electronic equipment
14 Petitioner claims an additional $250 exclusion from
income, relying upon documentary evidence that she paid that
amount for tickets to the Broadway show “M. Butterfly”. The case
of Mr. M. indicates, however, that petitioner charged her
customers what she paid for Broadway tickets. There is no basis
to assume otherwise in the case of the tickets for “M.
Butterfly”. Absent some proof to the contrary, we believe that
petitioner received full payment for those tickets, offsetting
the amount she used to buy them. There is thus no taxable event.
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