Karan M. Hintze - Page 8

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          from her parents, as opposed to the $2,502 allowed by respondent.           
          Petitioner produced what appears to be a financial spreadsheet              
          pertaining to her parents which reflects total distributions to             
          or for the benefit of petitioner during 1992 of $3,002.07.  Of              
          the $500.07 of such expenditures which respondent determined did            
          not warrant a reduction from gross receipts, $323.07 was paid to            
          third parties on petitioner’s behalf.  As those amounts were not            
          deposited to petitioner’s checking accounts, they do not support            
          a reduction from the gross receipts figure determined by                    
          respondent.  The remaining $177 in dispute consists of a                    
          purported distribution of $27 to petitioner on October 19, 1992,            
          as well as a purported $150 distribution to petitioner on                   
          November 26, 1992.  Petitioner, however, failed to establish that           
          these amounts were deposited to her checking accounts.                      
          Accordingly, petitioner is not entitled to a reduction from gross           
          receipts by reason of nontaxable transfers from her parents in              
          excess of the $2,502 allowed by respondent.                                 
               Third, petitioner contends that the reduction from gross               
          receipts on account of interaccount transfers should be                     
          $10,735.54 as opposed to the $8,775.54 reduction allowed by                 
          respondent for such purpose.  Petitioner introduced into evidence           
          bank statements indicating that $10,035.54 in transfers were made           

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