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tioners' bank deposits for 1988 constituted gross receipts of
Design Consultants for that year. Respondent then reduced the
gross receipts of Design Consultants that respondent determined
for 1988 by "Income per return" in order to determine Design
Consultants' unreported gross receipts for that year. Respondent
did not include in that "Income per return" figure the $49,525 of
1988 White Star compensation that petitioners reported on line
four of their 1988 Schedule C as "Other income". We find that
respondent made a computational error in applying the bank
deposits method to determine Design Consultants' unreported gross
receipts for 1988 (1988 computational error) in that respondent
should have included the 1988 White Star compensation in that
"Income per return" figure.15 Accordingly, we find that the
unreported gross receipts of Design Consultants for 1988 is
$178,594, and not $228,119. We further find that the amount of
the deficiency, and therefore the amount of the underpayment, for
1988 (revised 1988 underpayment), see sec. 6653(c)(1), should be
reduced in the Rule 155 computation in order to correct the 1988
computational error.
We shall now turn to the question of fraudulent intent. To
prove that an underpayment is attributable to the fraudulent
intent of the taxpayer, respondent must prove that the taxpayer
15 However, we sustain respondent's separate determination that
petitioners have unreported income for 1988 of $49,525 attribut-
able to the 1988 White Star compensation.
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