Friscia Construction, Incorporated, et al. - Page 9




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          Accordingly, we hold that the Friscias’ net income in 1994 from             
          the Amway distributorship was $9,676 ($46,172 - $36,496).                   
               3.   The 533 Account                                                   
               The Friscias deposited $33,645 into a bank account numbered            
          206084533 (the 533 account) in 1994.  The Friscias concede that             
          these deposits were wages received by Michael Friscia from                  
          Friscia Construction in 1994.                                               
               4.   The 864 Account                                                   
               The Friscias deposited $1,450 into a bank acccount numbered            
          100446864 (the 864 account) in 1994 and earned interest thereupon           
          of $17.  Respondent concedes that the Friscias made $1,300 in               
          nontaxable transfers into this account.  The Friscias presented             
          no evidence concerning the source of the remaining $150 in                  
          deposits.  Accordingly, $167 of the deposits and interest in the            
          864 account represents income taxable to the Friscias in 1994.              
               5.   The 898 Account                                                   
               The Friscias deposited $1,135 into a bank account numbered             
          100446898 (the 898 account) in 1994.  The Friscias have provided            
          no explanation for the source of these deposits.  Accordingly,              
          the full $1,135 in deposits represents income taxable to the                
          Friscias in 1994.                                                           
               6.   The 522 Account                                                   
               The Friscias deposited $53,516 into a bank account numbered            
          206084522 (the 522 account) in 1994.  Respondent concedes that              






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