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brief, respondent states: "These rents were generated from
properties belonging to either William or Gertrude Van Eck
[William's parents], Renate Hodges [Friedgard's mother] or Keith
Martin [Walter's friend]." Apparently, ownership of some or all
of such properties changed hands from Walter after 1982. We
accept as true respondent's statement as to post-1982 ownership
by others than Walter, and we find accordingly. Walter argues
that the income from such properties should be taxed to those
others, the post-1982 owners of the properties. Respondent
argues as follows:
Respondent admits that the rents from these
properties initially constituted gross income to
petitioners' parents, rather than petitioners. It
bears restating, however, that Walter Van Eck never
transferred a dollar of the net rents to petitioners'
parents or Keith Martin during any of the tax years at
issue. * * * Portions of the rents collected, after
being commingled with funds from other sources, were
spent upon mortgage and other expenses associated with
the properties. * * * The balance of the rents were
spent by petitioners for their own personal purposes,
together with the other funds they deposited as
"loans," "gifts," or funds belonging to other family
members. * * *
Respondent has failed to explain how income that was income
to others became income to Walter or Walter and Friedgard.
Apparently, respondent is frustrated with the difficulties that
her agents and attorneys encountered during the examination and
trial preparation phases of this case:
Respondent submits that the record morass created
by Walter Van Eck is so deliberately confounded, and
his credibility is so negligible, that we must reduce
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