- 26 - Commissioner's determination. See Alvarez v.Commissioner, T.C. Memo. 1995-414. The parties stipulated that nontaxable deposits were made into the shared bank account of Special Occasions and Special O. Respondent conceded that the total dollar amounts of unexplained bank deposits from the shared bank account should be reduced to $610 and $1,362 for 1992 and 1993, respectively, and that these amounts should be divided equally between Special Occasions and Special O. Petitioner presented no evidence to show that any other unexplained bank deposits into the shared account were nontaxable deposits. Petitioner failed to introduce cash register receipts, canceled checks, credit card statements, or bank deposit receipts to substantiate the source of unexplained bank deposits. Moreover, petitioner failed to convince the Court of any impropriety concerning respondent's equal division of taxable bank deposits between Special Occasions and Special O. As noted earlier, the funds of Special Occasions and Special O were commingled. Consequently, on this record, the Court sustains the amount of income determined (after concessions) by respondent in connection with Special Occasions and Special O for 1992 and 1993. The fourth issue is whether petitioner is entitled to a section 179 expense deduction for 1993 in connection with SpecialPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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