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financial activities of their enterprise, respondent conducted a
bank deposit analysis of the bank account petitioners used in the
operation of their sewing business. This analysis determined the
following deposits and source of funds:
1988
Source Amount
Pam's Closet $202,457.40
Donovan-Galvania 9,212.66
Byn-Mar, Inc. 30,205.48
Brenco Apparel, Inc. 19,676.35
Bently Arbuckle, Inc. 7,283.40
Jones of Dallas 4,288.75
H&A Fashions 4,675.34
Tu Van Le 9,000.00
Ruoc H. or Thim T. Doan 2,000.00
Cash 5,000.00
Various 9,784.58
303,583.96
1989
Pam's Closet $111,670.90
Marlin Manuf. Co. , Inc. 8,103.00
Tam Van Nguyen 2,000.00
Dau Thi Bui or Tuan Ngoc 2,000.00
Various 4,500.00
128,273.90
After concessions by both parties regarding the above
figures, only two deposits remain in dispute; both deposits
occurred in taxable year 1988 and totaled $14,000. Remaining in
dispute are: (1) The $9,000 deposit, identified above as
received from Tu Van Le; and (2) the $5,000 deposit identified
above as cash. Petitioners, maintaining that both deposits
represent nontaxable loans, did not report the $14,000 on their
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