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nontaxable transfer of receipts from their timber sales. Mr.
King testified that he put receipts from timber sales before 1995
into their appliance business. Mrs. King testified that money
from timber sales during the years in issue was deposited in
their farm account, and that she transferred it to the King’s
Appliances account as needed. Petitioners did not state or
provide any records showing how much money they transferred.
Petitioners contend that respondent failed to prove that the
$9,650 was from a taxable source. Respondent linked petitioners
to several income-producing activities, and thus the deficiency
determination is presumed to be correct and petitioners have the
burden of proving that the $9,650 was from a nontaxable source.
See Blohm v. Commissioner, supra. Petitioners did not do so. We
conclude that petitioners had unreported cash income of $9,650 in
1995.
2. Whether Respondent Correctly Determined Petitioners’
Gross Receipts From Sales for 1996-97
Petitioners dispute respondent’s determination that they had
unreported income from layaway sales in the amounts of $6,671 in
1996, and $467 in 1997. Petitioners contend that the amounts
determined by respondent are greater than the amounts stated on
petitioners’ computerized general ledger which petitioners
installed at respondent’s request. However, the computerized
general ledger is not in the record, petitioners did not state
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