Walter Van Eck and Friedgard Van Eck - Page 21

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          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.                                                                  
               Respondent's theory is that the Reprographics Plastics'                
          deposits were expended for the benefit of Walter and Friedgard              

               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.                             

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