Appellants' Reply Brief - Washington State Courts

economic success. See Exs. 19, 20; Hallett 75-77, 92. These too
represent business expenditures that should be deducted from Malang's
gross receipts to most accurately capture her lost earning capacity. These
same principles apply to the other business expenses that Malang declared
on her Schedule C. These expenses contributed to Malang's ability to
generate the gross receipts disbursed to her.
Malang also asserts that "[tlax return preparation is not an expense
ofproducing income; it is a consequence of income." RB at 35. And she
asserts that gifts for clients and contributions to the community relate to
business that she "already had, so this cost was not an expenses [sic] of
producing earnings." RB at 36. In both respects, however, she missed
dates the purpose of the expenditures, which was to ensure that her
business enterprise continue to generate income in the future. She made
these expenditures because she wanted to generate even more new
business from her past and present clientele.
Finally, Malang appears to be confused when she quotes from
Board discussion in In ve Daniel A. Renshaw, BIIA Dckt. Nos. 02 16572,
02 16573,2003 WL 22479584 (Aug. 27, 2003), regarding a deduction the
employer made, per a collective bargaining agreement, from a union
worker's cash wage to an account. RE3 at 35. The Board held that under
the circumstances of that case the deduction resembled direct deposit of