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Under the other variation of the analysis, respondent
contends that Mr. Sasser had at least $6,730 of unreported income
in 1996:
Deposits to personal account $29,096
Less: Mrs. Sasser’s net wages -17,267
Balance 11,829
Less: Dec.‘96 credit card advance - 11,500
Balance 10,329
Less: Deposits attributable to
Mrs. Sasser’s brother -13,600
Unreported gross receipts 6,729
1If proven
Neither variation of respondent’s bank deposits analysis
takes into account the $1,730 tax refund that petitioners
received in 1996. This “omission” is appropriate because the
refund was not deposited in either of petitioners’ checking
accounts and therefore need not be accounted for insofar as the
bank deposits analysis is concerned.
The gross receipts reported by Mr. Sasser on his Schedule C
were also not taken into account by either variation of
respondent’s bank deposits analysis. In this regard,
respondent’s position seems to be that there was no commingling
of Mr. Sasser’s gross receipts between petitioner’s personal and
business checking accounts. However, this position is contrary
to the weight of the evidence, and our findings reflect the fact
that Mr. Sasser’s gross receipts were commingled between
petitioners’ two accounts.
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Last modified: May 25, 2011