Walter Van Eck and Friedgard Van Eck - Page 17

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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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