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from savings account 355 to checking account 355 during 1992.4
Given that respondent conceded that all deposits to savings
account 355 represent nontaxable income, petitioner is entitled
to an additional $1,260 reduction to the gross receipts figure
determined by respondent.
In summary, respondent’s determination that petitioner
received failed to report $13,437.62 of gross income during 1992
is sustained to the extent of $12,177.62.
2. Adjustments for 1994 Tax Year
Similar to his calculations for the 1992 tax year,
respondent’s reconstruction of petitioner’s gross income for 1994
was limited to the deposits made to petitioner’s checking
accounts. Respondent determined that petitioner made $40,221.57
in deposits to checking account 355 and $53,026.68 in deposits to
checking account 317 during 1994.5 From the $93,248.25 in gross
receipts, respondent subtracted $40,988.94 for deposits
identified as representing receipts of nontaxable income.
Respondent therefore determined that petitioner recognized gross
income from her business of $52,259.31 as opposed to $44,126
reported by petitioner.
4 We cannot account for the $700 discrepancy between what
petitioner claims should be the reduction from gross receipts for
interaccount transfers and the amount of such transfers reflected
on the bank statements.
5 As explained supra note 3, petitioner does not challenge
the calculation of total deposits.
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