- 41 - petitioners contend that respondent made a computational error in applying the bank deposits method for 1988 in that, in determin- ing the unreported gross receipts of Design Consultants under that method, respondent failed to reduce the bank deposits that respondent determined were Design Consultants' gross receipts for that year by the $49,525 of 1988 White Star compensation that petitioners reported in their 1988 Schedule C. We agree that respondent made a computational error in applying the bank deposits method to determine the amount of Design Consultants' unreported gross receipts for 1988. Respondent's determinations in the notice of Design Consul- tants' unreported gross receipts were based on the bank deposits method analysis conducted by Mr. Kaply. As is reflected in the 1988 explanation, respondent determined the total amount that petitioners deposited into their bank accounts for that year and the portion of those deposits that constituted gross receipts of Design Consultants. In determining the portion of petitioners' total bank deposits for 1988 that constituted gross receipts of Design Consultants, respondent reduced the total amount of petitioners' bank deposits that respondent determined for that year by what respondent determined to be petitioners' deposits from nontaxable sources, transfers that petitioners made between their bank accounts, the total amount of petitioners' rental income, and "Wages" consisting of the $49,525 of 1988 White Star compensation. Respondent determined that the balance of peti-Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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