- 9 -
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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