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did Walter Van Eck receive hundreds of thousands of
dollars in loans and gifts from family members during
the tax years at issue, or is he engaged in some income
producing activity which he and his relatives are
concealing from respondent?
Respondent speculates as to that income producing activity:
The Van Eck family, as one integrated unit, could be
selling anything from molded plastic products [a
business of Walter's brother Jan, whose business
ventures respondent describes as "generally not
successful"] to prescription medication [Walter's
parents were both physicians]. * * * Walter Van Eck
could be selling anything from tax and financial
management services to money laundering systems
developed on his computers. * * *
Specifically, respondent argues that portions of the GVE Loans
(and certain other amounts from either Gertrude or William)
should be deemed compensation from Gertrude or William for
property management services. Indeed, Walter testified that,
although he did not have specific recall, withdrawing funds from
Conn. account 7044 for fees due for management services would be
the way such fees would be paid by his mother. Respondent has
computed management fees due Walter from his parents and Keith
Martin to be at least:
Year Amount
1982 $2,072
1983 757
1984 1,527
1986 303
1987 1,887
Respondent also argues that other portions of the disputed
deposits may be deemed fees paid to Walter for tax management and
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