- 13 -
During 1993, four bank accounts were maintained as personal
accounts of petitioners, and three were maintained in the name of
the sole proprietorship. Total deposits of $943,147 were made
into these accounts in 1993. After subtracting $281,708 for
interaccount transfers, $269,551 for loans, $30 for overdrafts,
and $7,023 for other nontaxable items, Ms. Nierich calculated net
taxable deposits of $384,835. Excluding the $244,270 of gross
receipts listed on the LeBouef Company Schedule C, petitioners
reported total gross income on their 1993 return of less than
$60,000, a difference of more than $300,000 when compared to the
bank deposits analysis.
While respondent does not treat this as an unreported income
case and is not attempting to tax petitioners on receipts not
shown in their own return, the analysis performed does buttress
the conclusion that petitioners and/or their sole proprietorship
received substantial moneys which would escape taxation if we
were to accede to their version of the facts before us.
Furthermore, we note that although petitioners dispute several
aspects of the bank deposits analysis, they have offered no
documentary evidence tracing any particular deposits to
nontaxable sources and, thus, have not substantiated their
allegations that certain additional amounts should be treated as
nontaxable.
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011