Anthony G. and Shirley A. Olbres - Page 41

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          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-              




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