- 20 -
Walter signed all of the checks drawn on FIB 1276 during 1986 and
1987. On March 9, 1987, a check in the amount of $10,000 drawn
on an account of William's at First Bank of New Haven was
deposited to FIB account 1276. On March 19, 1987, a check drawn
on FIB account 1276 to Walter Van Eck was deposited to an account
of Friedgard's at U.S. National Bank. The $10,000 amount shown
on Exhibit 201-GK in the row labeled "WFVE Loans" reflects the
deposit into FIB account 1276, on March 9, 1987, of the $10,000
check drawn on William's account at First Bank of New Haven.
OPINION
The amounts shown on Exhibit 201-GK as WFVE Loans and WFVE
Gifts (the WFVE Loans and Gifts) represent deposits to bank
accounts under the control of Walter: in essence, Walter's
accounts. Respondent's arguments with respect to the WFVE Loans
and Gifts are precisely the same as with respect to the GVE
Loans, and our response is precisely the same. The WFVE Loans
and Gifts do not constitute items of gross income to Walter.
6. Reprographics Plastics Deposits
FINDINGS OF FACT
On October 30, 1985, a checking account in the name of
Reprographics Plastics Corporation (Reprographics) was opened in
Oregon, at U.S. Bank, account number 155-0010-894 (USB account
0894). Walter prepared and signed all checks, made all of the
deposits, and maintained all of the bank records for USB account
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