- 21 -
0894. During 1985, 1986, and 1987, payments were made from USB
account 0894 for the benefit of Walter and Friedgard.
Reprographics was a Canadian corporation during the years at
issue. Jan, Walter's brother, was president of Reprographics.
Reprographics has never been registered as an entity authorized
to do business in the State of Oregon.
The amounts shown on Exhibit 201-GK in the row labeled
"Reprographics Plastics" reflect certain deposits to USB 0894.
The amounts remaining in dispute as Reprographics Plastics'
deposits (the Reprographics Plastics's deposits) are as follows3:
Year Amount
1985 $1,200.00
1986 8,333.80
1987 35,000.00
The Reprographics Plastics' deposits were deposited to USB
account 0894 during the years indicated. All of the
Reprographics Plastics' deposits constitute items of gross income
to Walter.
OPINION
Respondent's theory is that the Reprographics Plastics'
deposits were expended for the benefit of Walter and Friedgard
3
Except with regard to 1987, our findings agree with entries
for 1985 through 1987 in the row labeled "Reprographics Plastics"
on Exhibit 201-GK. The discrepancy arises because of
respondent's concession on brief that "$7,500 of the $42,000
total 1987 disputed Repro deposits should be eliminated as a
gross income item." We accept that concession.
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011