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$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 fiscal
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