Business receipts, including the monthly rent checks from T, are deposited into the business account. Business expenses, such as the general excise tax for which the CRAT is liable, are paid out of the business account. Income from the bonds is deposited into the investment account. There are no facts indicating that funds in the two account are commingled. None of the assets in the investment account is used as business capital.
Interest paid on the business account is subject to the general excise tax.
Interest paid on the bonds, and interest paid by the bank on the investment account, are not subject to the general excise tax.