-28- for that payment. We also note that petitioners never intermingled their funds in a joint account, but kept their financial accounts separate, and that petitioners’ relationship throughout the subject years was one in which they each understood that they were responsible for the payment of their share of the expenses. We hold for petitioners on this item.11 3. VISA advances Petitioners argue that they are entitled for 1997 to an adjustment of $2,500 for VISA advances. Respondent concedes that this $2,500 is not taxable income to petitioners, and we so hold. 4. Sales Tax Remittances Petitioners argue that they are entitled for 1997 to an adjustment of $3,800 for sales tax remittances for October and November 1997. We agree. Michelsen operated the Nature’s Touch shops as a sole proprietorship from January 1 through November 23, 1997, and she (as a conduit) collected sales tax on the sales made at the shops during that time. She deposited the collected sales tax into the shops’ business account and later remitted that tax to the State of California. Respondent’s bank deposits analysis for 1997 made an adjustment for sales tax 11 Whereas we understand petitioners to request that we also hold that other amounts reported as compensation from NT were actually loan repayments, we decline to do so. Michelsen was the sole reported recipient of compensation from NT, and petitioners make no assertion in this proceeding that Michelsen lent money to NT.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: November 10, 2007