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b. IRS Determination for 1992
The internal revenue agent determined petitioners' gross
income from Raymond's sale of sports memorabilia and supplies for
1992 as follows:
Ameritrust deposits $77,482
Less misc. expenses (2,934)
Star Bank deposits 17,424
Total 91,972
The agent did not reduce the gross income to reflect the
$885.86 miscellaneous expenses from the Star Bank account.
The agent determined that petitioners' 1992 income should be
increased by $26,023 computed as follows:
Gross receipts $91,972
Purchases (58,971)
Rent (5,000)
Self-employment tax adjustment (1,978)
Total 26,023
Of the $58,971 allowed for purchases, checks totaling
$18,130 were dishonored due to insufficient funds.
J. Barbara Kling
Barbara knew that Raymond bought and sold sports memorabilia
during the years at issue, that he stored the memorabilia at the
warehouse and at St Vladimir's, and that he maintained the
Ameritrust and Star Bank accounts.
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