- 24 -
discussion at proposed finding #XIX)." Petitioners have made no
such proposed finding.
We have found that the Reprographics Plastics' deposits were
deposited to USB account 0894. We are convinced that Walter had
control and authority over USB account 0984 that amounted to
ownership of that account. As we have stated, bank deposits are
prima facie evidence of income. Tokarski v. Commissioner, supra
at 76. Petitioners have failed to rebut the prima facie evidence
that the Reprographics Plastics' deposits were gross income to
Walter. Moreover, petitioners deny that, during 1985, 1986, and
1987, payments were made from USB account 0894 for the benefit of
one or the other (or both) of them. We have found to the
contrary. Thus, even if we assume that Walter was not the owner
of USB account 0894, petitioners have failed to prove that some,
or all, of the expenditures made from that account were not gross
income to one or the other of them. We sustain respondent's
determinations of deficiencies to the extent based on the
Reprographics Plastics' Deposits.
7. Unknown Source Deposits
a. 1982
FINDINGS OF FACT
During at least the first 5 months of 1982, Walter and
Kosydar (his then wife) maintained a joint checking account in
Oregon, at U.S. Bank, account number 155-0501-348 (USB account
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