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balances in his three accounts by a combined total of $104,063.
In other words, in each year the bonding fees that petitioner
deferred reporting exceeded the amount reported. The instant
case involves the systematic, consistent treatment of a
significant item, not a posting or computational error. See sec.
1.446-1(e)(2)(ii)(b), Income Tax Regs. Petitioner’s treatment of
the deposits was not “error” within the meaning of this
regulation.
Petitioner’s Additional Arguments
Petitioner presents numerous additional arguments, none of
which are persuasive. Petitioner directs his first argument to
the Charleston County Court account only and argues that, because
the receipt of fees and the subsequent deposit of moneys into the
account were interrelated, the receipt of amounts deposited was
of “no moment”, and petitioner was not required to include it in
income. Petitioner is wrong on the facts. Petitioner was
required to maintain deposits with the Clerk of Court of
Charleston County in the amount of 25 percent of outstanding
bonds. He collected as a fee 10 percent (sometimes less) of each
bond he wrote. There was no relationship between the deposits
and the fees. There was no requirement that petitioner pay a
percentage of the fees he collected into the Charleston County
Court account, unlike the taxpayers in Sebring v. Commissioner,
93 T.C. 220 (1989), and Rankin v. Commissioner, T.C. Memo. 1996-
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