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Petitioner paid $50 per day for about 250 days per year to
each of two individuals to help him with the business (e.g.,
unloading containers) in 1993-95.
4. Petitioner’s and Ms. Shaw’s Bank Accounts
During 1993-95, petitioner was a signatory on six bank
accounts (petitioner’s bank accounts) that he used for his
business.
Ms. Shaw also had a business bank account. Some of the
gross receipts from her store were deposited in petitioner’s bank
accounts in 1993-95.
The following amounts were deposited in petitioner’s bank
accounts: $549,478 in 1993, $612,380 in 1994, and $603,049 in
1995.1 These deposits included some of Ms. Shaw’s income from
the Bourbon Street store, which was nontaxable to petitioner, and
the following additional amounts that are nontaxable to
petitioner:2
1 This included some deposits of income from Ms. Shaw’s
business, which respondent concedes is a nontaxable source for
petitioner.
2 Respondent concedes that the following amount of Ms.
Shaw’s income was deposited in petitioner’s bank accounts:
$38,834 in 1993, and $12,085 in 1994, and that those deposits
were not taxable to petitioner. Petitioner contends that more
than $38,834 of Ms. Shaw’s gross receipts was deposited in his
bank accounts in 1993. We discuss petitioner’s contention below
in par. B-1 of the opinion.
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