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Walter by attacking his veracity. In evidence is an affidavit of
Walter's made in connection with his divorce from Kosydar. Joint
Exhibit 136-EF. That affidavit is dated July 17, 1987. In that
affidavit, Walter declares, among other things: (1) "The number
and amount of loans * * * from my parents has steadily decreased,
and has reached the point of zero" and (2) "My parents' financial
condition has deteriorated sharply in the last years, and they
are virtually insolvent, with no cash assets of any kind
available."
The parties have stipulated that, if Gertrude were to
testify, she would testify that, during 1991 and other years, she
borrowed money from third parties and, thereby, was able to make
loans to Walter.
There is no question but that the amounts shown on Exhibit
201-GK as GVE Loans (the GVE Loans) represent deposits to bank
accounts of Walter's. We have said: "A bank deposit is prima
facie evidence of income and respondent need not prove a likely
source of that income." Tokarski v. Commissioner, 87 T.C. 74, 77
(1986). Here, however, we know the source of the deposits, at
least in the sense of knowing from whom they came, Walter's
mother. Given the conclusions naturally to be drawn from a
transfer of funds from a parent to a child, respondent does not
rest on the fact of the deposits as establishing income.
Respondent posits the necessary further inquiry as to the GVE
Loans and other amounts received from family members as follows:
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