Walter Van Eck and Friedgard Van Eck - Page 3

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          deposit analysis for the years 1982 through 1987, and (3) the               
          disallowance of a deduction claimed in 1987.  Petitioners filed a           
          single petition in response to both notices of deficiency.  Prior           
          to and during the trial of this case, the parties entered into a            
          series of stipulations that resolved all adjustments associated             
          with the disposition of real property and substantially reduced             
          the amounts of bank deposits that are in dispute.  On brief,                
          respondent has conceded that certain additional deposits                    
          represent nontaxable items to petitioners and that the addition             
          to tax under section 6661 no longer is applicable.  We accept               
          such concessions.  Several items relating to respondent's bank              
          deposit analysis and the disallowed deduction remain for                    
          decision, as do the additions to tax under sections 6651 and                
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years at issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.  Our findings of fact and opinion for each issue are             
          set out separately.                                                         
                            PRELIMINARY FINDINGS OF FACT                              
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact filed by the parties and attached                  
          exhibits are incorporated herein by this reference.                         

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