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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 Special
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