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separately deposited into an account styled in the business name;
(b) not all the net business income was deposited into the joint
household account; (c) Mrs. Shea did not have signing authority,
access, or knowledge of the specific transactions in the business
account; and (d) Mrs. Shea did not involve herself in the
business and did not know the extent of the gross income or the
extent of the unreported income of the business.
The facts on which respondent relies, either taken alone or
taken together, do not justify the conclusion that petitioner
acted as if he were solely entitled to business income. The fact
that business gross receipts are deposited into a business
account is in accordance with normal business practice. Mrs.
Shea was clearly aware of the existence of petitioner's business
and its bank account. The fact that not all the business income
was deposited into the household account is, of itself,
unremarkable. We would not find it at all unusual if less than
the net profit was so deposited. The fact that Mrs. Shea did not
have signing authority over the business account is likewise
unremarkable given the fact that she had little day-to-day
involvement in the operation of the business. Finally, the fact
that Mrs. Shea did not know the extent of business income is not
proof that petitioner was acting as if he were solely entitled to
the income. Without more, it does not support respondent's
allegation that the income was "hidden" from her.
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