- 8 -
all of those deposits by either check or withdrawal, leaving a 1994
ending balance of $853. The following is a summary of the checks
drawn on the JJH account during 1994:
PAYEE/CATEGORY AMOUNT PERSONAL BUSINESS
Petitioner $4,680 $4,680 -0-
Charlene 7,725 7,725 -0-
Coastal 18,525 18,525 -0-
CCA 8,375 8,375 -0-
Craig 1,950 1,950 -0-
Tim 14,454 14,454 -0-
Walt Disney World 4,869 4,869 -0-
Utilities1 6,768 4,125 $2,643
Lewis Simmons2 8,780 5,853 2,927
Internal Revenue Service 4,570 4,570 -0-
Other3 63,514 21,979 41,535
Total 144,210 97,105 47,105
1The total electric, gas, and water bills of the Muehl
residence were $3,948. We allocate one-third to business use and
two-thirds to personal use as there are no separate meters for
the basement of the residence, and petitioner has provided no
credible evidence that this allocation, which was proffered by
respondent, is improper. The balance of the utilities expense
comprises telephone expenses allocated $1,362 to personal use and
$1,458 to business use.
2This represents rent for the Muehl residence, allocated
one-third to business and two-thirds to personal.
3We allocate the following payment categories 100 percent to
personal: River Park Apts, $1,360; insurance, $8,631; medical,
$2,130; misc. expenses petitioner admits are personal, $3,621.
We allocate the following payment categories 100 percent to
business: Charles Losa, $5,276; Tax Court, $300; Dir. of Labor,
$39; misc. payments, $10,581; Office Max, $598; S.W. Financial,
$1,818; various individuals, $3,677; Cindy Manzzi, $4,485;
Postmaster, $2,526. On the basis of a reasonable estimation and
lack of exact substantiation in the record, we allocate the
following payment categories 50 percent to business and 50
percent to personal (amount stated is the total expense): Credit
cards, $6,468; Hintze Auctions, $4,360; cable, $953; automotive
related, $12,690.
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