- 14 -
were deposited to Conn. account 7044 except for $2,500 and $500
deposited to USB account 2221 in 1983 and 1984, respectively. Of
those amounts, the following amounts constitute fees for
management services rendered by Walter:
Year Amount
1982 $2,072
1983 757
1984 1,527
1986 303
1987 1,887
OPINION
The label "GVE Loans" stands for Gertrude Van Eck loans,
which, respondent argues, is a misnomer. Respondent discusses
the GVE Loans as follows:
Walter Van Eck never provided the Court with a summary
of all of the loans he allegedly obtained from Gertrude
Van Eck during the tax years at issue. Respondent has
never undertaken the Herculean task of determining the
alleged loan amounts from Walter Van Eck's records.
The heading [GVE Loans], instead, largely refers
to the number of deposits which were made into Walter
Van Eck's Connecticut account, Conn-7044. * * *
Respondent initially understood that the Conn-7044
account was exclusively used as a loan account between
Gertrude and Walter Van Eck. Respondent accordingly
deemed all of the deposits into Conn-7044 to be alleged
loans.
Respondent subsequently discovered that the Conn-
7044 account was also used for a variety of other
purposes. It was used to transmit funds allegedly
originating from William Van Eck to Walter Van Eck. It
was also used as a vehicle for transferring funds from
Connecticut to the Oregon bank accounts to satisfy
expenses arising from the rental properties belonging
to William and Gertrude Van Eck. * * *
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