Luis Acle, Jr. - Page 9

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          Schedule C was filed for OU rather than for NAFTA.  Petitioner              
          reported Schedule C gross receipts of $116,280 and claimed                  
          deductions totaling $123,040 for various expenses, for an overall           
          loss of $6,760.  One of the expenses claimed as a deduction by              
          petitioner is in the amount of $17,000 and is described as                  
          “administrative Mexico”.                                                    
               In the notice of deficiency, respondent determined that                
          petitioner received $144,102 in unreported income from his                  
          business activities.  Respondent calculated this amount as                  
          follows:                                                                    
               Bank deposits                              $325,155                    
               Less transfers between accounts              26,095                    
               Less line of credit advances                 38,678                    
               Less gross receipts reported on return      116,280                    
               Unreported income                          $144,102                    
          Respondent now concedes that the amount of unreported income                
          should be reduced by $7,745 to $136,357 to reflect credit card              
          overdraft transfers into petitioner’s accounts.  Respondent also            
          disallowed in the notice of deficiency the $17,000 deduction                
          claimed by petitioner as “administrative Mexico”.  Respondent               
          allowed the deductions for each of the other expenses claimed by            
          petitioner on the Schedule C.                                               












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