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tax shelter services rendered to his parents. Respondent
suggests no amounts for such services.
Suspicions are not proof. The GVE Loans were received by
Walter from his mother. Neither gifts nor loans constitute items
of gross income. Sec. 102(a) (gross income does not include
gifts); e.g., Ettig v. Commissioner, T.C. Memo. 1988-182 (bank
deposits in question were, in fact, loan proceeds received from
taxpayer's mother and, thus, not items of gross income). Except
to the extent that there is a reason to believe to the contrary,
we believe that the transfers from Walter's mother into Walter's
bank accounts were either gifts or loans. We have found to the
contrary to the extent that respondent has convinced us that
Walter received fees for management services.2 Except to that
extent, Walter has carried his burden of proof that the GVE Loans
do not constitute items of gross income to him.
4. Triad Distribution
FINDINGS OF FACT
In 1982, a bank check in the amount of $1,000 drawn on Triad
Distribution Co. was deposited by Gertrude into Conn. account
7044. The amount shown on Exhibit 201-GK in the row labeled
"Triad Distribution" reflects that deposit (the Triad deposit).
2 We recognize that respondent maintains that the management
fees in question constitute fees received from Gertrude, Walter,
and Keith Martin. Walter has not shown what portion is allocable
to Gertrude and, because of the relative smallness of the amounts
involved, we have not estimated. But cf. Cohan v. Commissioner,
39 F.2d 540, 543-544 (2d Cir. 1930).
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