- 7 - Commissioner, 96 T.C. 858, 868 (1991), affd. 959 F.2d 16 (2d Cir. 1992). Petitioners kept no books of account for their Schedule C pallet business. Records for the pallet business consisted of petitioners’ checkbook, invoices for sales of pallets dated for the months of April through November 2002, and purchase orders for pallets dated for the months of February, March, May, July, and October through December of 2002. Petitioners reported gross receipts of $3,638 on Schedule C. Petitioners’ invoices for sales of pallets for 2002 total $3,400. Respondent was unable to determine from petitioners’ records whether they deposited their gross receipts into their bank accounts. He therefore treated the amounts shown on the invoices for sales of pallets as cash that was not deposited to their bank accounts. Mrs. Runels testified, however, that she commingled payments from the pallet business with their personal funds. But when Mrs. Runels was asked at trial to identify in her bank records for 2002 deposits of any of the amounts shown on the invoices for sales of pallets, she was unable to do so. Petitioners argue that respondent’s bank deposits analysis was incorrect because it double counted bank deposits by including bank transfers. Mrs. Runels, however, testified that she conferred with the TCO and with counsel for respondent to demonstrate which items were transfers. Respondent took intoPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008