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$3,600 was automatically transferred from petitioner’s corporate
business bank account into one of petitioner’s personal bank
accounts. During each such year, petitioner and his spouse used
petitioner’s personal bank accounts primarily for the payment of
their personal expenses.
In order to calculate the gross receipts that petitioner
derived from petitioner’s sole proprietorship during each of the
years at issue, respondent used the bank deposits method with
respect to petitioner’s corporate business bank account and
petitioner’s personal bank accounts. According to the bank
deposits method, petitioner had the following gross deposits,
nontaxable deposits, and gross receipts derived from petitioner’s
sole proprietorship for each of the years at issue:
Year Gross Deposits Nontaxable Deposits Gross Receipts
1995 $481,365.17 $47,058.58 $434,306.59
1996 341,029.75 31,000.00 310,029.75
1997 490,908.45 151,000.00 339,908.45
In addition to using the bank deposits method in order to
calculate the gross receipts that petitioner derived from peti-
tioner’s sole proprietorship during each of the years at issue,
respondent used billing invoices and/or purchase orders generated
by that business (petitioner’s billing invoices and/or purchase
orders) in order to calculate such gross receipts. According to
petitioner’s billing invoices and/or purchase orders, petitioner
had the following gross receipts derived from petitioner’s sole
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