- 37 - $2,712,461.27 in Kenmore’s fiscal 1982. Supra table 5. They also have stipulated that, of these amounts, at least $58,587.62 for fiscal 1981 and $52,244 for fiscal 1982 are nontaxable deposits. The accounts receivable amounts used in calculating the increase in gross receipts, as shown supra in table 5, are taken from Kenmore’s tax returns and are not disputed by either side. We conclude, and we have found, that Kenmore’s various business activities are collectively the source of its unreported income. As discussed infra, we also conclude that none of the suggested nontaxable sources explains Kenmore’s unreported income, except for Gleave’s apparent deposits of $6,600 payments on a purchase-money mortgage from the sale of Ted’s Nursery. Kenmore contends that because Broskin used Kenmore’s lines of credit and charged fuel at the refineries to Kenmore, Broskin’s money was just passing through Kenmore’s Account, and thus the amounts deposited into Kenmore’s Account that came from Broskin should not be included in Kenmore’s gross receipts, because these amounts are income of Broskin. We have found that, when Broskin used Kenmore’s lines of credit and charged fuel at the refineries to Kenmore, then Kenmore paid the refineries for this fuel, and Broskin paid Kenmore for this fuel. So, although payments by Broskin deposited into Kenmore’s Account are included in the total deposits to Kenmore’s Account for its fiscal 1981 and its fiscalPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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