Charles Shaw - Page 7

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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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