Wayne Payne and Dorene J. Payne - Page 19

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          ordinary and necessary expenses of running petitioners’ business.           
          See sec. 162.  HRDC maintained a checking account to which                  
          petitioners could have deposited the money from the extras for no           
          charge.  Petitioners testified that they cashed checks at the               
          Money Exchange because they knew the owner and it was within                
          blocks of the office (although Mr. Payne, who did not drive,                
          needed someone to drive him there each time he went).  It is                
          obvious that petitioners used the Money Exchange to avoid the               
          inclusion of the income in their bank records.  These reasons are           
          not related, let alone ordinary and necessary, to HRDC’s                    
          business.  Therefore, petitioners are not entitled to deduct the            
          cost of check-cashing fees.                                                 
          V.   Unreported Additional Bank Deposits                                    
               Respondent adjusted petitioners’ income by $3,681 for 1993             
          and $30,953.94 for 1995 for bank deposits made to their account             
          in excess of all identified sources, including extras and income            
          from HRDC.  Bank deposits are prima facie evidence of income.               
          Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).  Petitioners               
          stipulated that the deposits were made to their account, but they           
          reserved the right to show that two of the deposits were from               
          nontaxable sources.  On brief, petitioners conceded that the                
          $3,681 is includable in their 1993 income.  At trial, Mrs. Payne            
          testified that a deposit of $850 in 1995 was from Mr. Payne’s               
          sale of a gun to a sporting goods store.  Mrs. Payne also                   

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