Page:T.C. Memo. 2012-281.pdf/18

[*18] petitioner maintained a piano lesson business at her home. On the Schedules C attached to her Forms 1040, U.S. Individual Income Tax Return, petitioner reported business income from her piano lesson business. Petitioner also reported “other income”, ranging from $14,403 to $15,707, attributable to “[p]ersonal use CSE residence”, “[p]ersonal use CSE auto”, and “[o]ccupancy of living space”.

On November 20, 2009, respondent issued to petitioner a notice of deficiency for the years at issue. Respondent undertook to reconstruct income generated from CSE activities by analyzing deposits into the joint accounts of petitioner and Mr. Hovind, petitioner’s and Mr. Hovind’s personal accounts, and the CSE accounts during the years at issue. Respondent excluded from taxable net deposits the items that constituted refunds or transfers from another account. ___________