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[*19]
Respondent determined the taxable net deposits into the various bank accounts[1] as follows:
| Joint accts. | Personal acct. | CSE accts. | ||||
|---|---|---|---|---|---|---|
| Year | 8049 | 0811 | 5201 | 8656 | 1872 | Net deposits |
| 1998 | $50,364 | $2,161 | $639 | $595,001 | -0- | $648,165 |
| 1999 | 29,424 | 1,580 | -0- | 1,154,039 | -0- | 1,185,043 |
| 2000 | 54,450 | -0- | 772 | 1,690,078 | -0- | 1,745,300 |
| 2001 | 39,265 | -0- | -0- | 1,602,251 | -0- | 1,641,516 |
| 2002 | 24,170 | -0- | -0- | 1,778,824 | $40,896 | 1,843,890 |
| 2003 | 22,030 | -0- | -0- | 1,379,678 | 493,956 | 1,895,664 |
| 2004 | 11,398 | -0- | -0- | 1,466,762 | 641,133 | 2,119,293 |
| 2005 | 8,666 | -0- | -0- | 1,515,866 | 749,495 | 2,274,027 |
| 2006 | 3,463 | -0- | -0- | 1,003,370 | 517,661 | 1,524,494. |
In part on the basis of the deposits analysis summarized above, respondent determined that CSE had gross receipts[2] and deductible expenses[3] as follows:
- ↑ Respondent determined that all deposits into account 5129, a CSE account, were nontaxable transfers. Respondent determined that account 5129 earned $707, $2136, and $2 in interest income in 2000, 2001, and 2002, respectively. Respondent did not include the interest income in calculating CSE’s net taxable deposits. Respondent determined that there were no taxable deposits into account 8577, a CSE account.
- ↑ Respondent reduced CSE's Schedule C gross receipts by the amounts of gross receipts petitioner reported on the Schedules C attached to her untimely filed returns.
- ↑ To calculate operating expenses, respondent determined CSE's average operating expenses for 1998-99 and calculated the ratio of operating expenses to gross receipts. Respondent used this ratio to calculate operating expenses for 2000-06.
