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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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