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$187,331.24, including $14,969.51 of nontaxable items and $10,565
of transfers. Based upon the amounts stipulated, respondent
determined that petitioners had gross receipts of $115,528.02 in
2000 and that petitioners had gross receipts of $161,796.73 in
2001.5 As noted above, petitioners reported gross receipts of
$77,894 in 2000 and $114,589 in 2001. In light of the parties’
stipulations, we conclude that petitioners have failed to meet
their burden of proving that respondent erred in determining that
petitioners understated their 2000 gross receipts by $37,634.02
and their 2001 gross receipts by $47,207.73.
With respect to petitioners’ business expenses, respondent
allowed deductions of $4,419 for the 2000 tax year and $15,278
for the 2001 tax year, based upon the amounts that Agent Gomez
identified from the bank statements as business-related payments.
Although petitioners claimed business expense deductions of
$66,215 for the 2000 tax year and $101,024 for the 2001 tax year,
petitioners did not identify such expenses from the bank
statements when Agent Gomez provided them with the opportunity to
do so. At trial, petitioners were unable to provide any credible
5Respondent’s determination that petitioners had gross
receipts of $115,528.02 in 2000 represents the total deposits
into accounts A and B during 2000 ($222,467.13), less nontaxable
items ($90,804.03) and transfers ($16,135.08). Similarly,
respondent’s determination that petitioners had gross receipts of
$161,796.73 in 2001 represents the total deposits into accounts A
and B during 2001 ($187,331.24), less nontaxable items
($14,969.51) and transfers ($10,565).
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