Walter Van Eck and Friedgard Van Eck - Page 1

                                 T.C. Memo. 1995-570                                  


                               UNITED STATES TAX COURT                                


                WALTER VAN ECK AND FRIEDGARD VAN ECK, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8666-92.           Filed November 29, 1995.                 


                    R determined deficiencies in income tax based in                  
               part upon:  (1) a bank deposit analysis for the years                  
               1982 through 1987, and (2) the disallowance of a                       
               deduction claimed in 1987.  Respondent also determined                 
               additions to tax under sec. 6651, I.R.C., for failure                  
               to file, and sec. 6653(a), I.R.C., for negligence.                     
                    1.  Held:  Ps have in part carried and in part failed             
               to carry their burden of proving that the income items                 
               in dispute were not gross income to them.                              
                    2.  Held, further, R's determination of additions                 
               to tax under sec. 6651, I.R.C., are sustained.                         
                    3.  Held, further, R's determination of additions                 
               to tax under sec. 6653(a), I.R.C., are sustained.                      

               Walter Van Eck and Friedgard Van Eck, pro sese.                        
               Catherine J. Caballero and Jeffery M. Wong, for respondent.            






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