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                                       OPINION                                        
               Respondent proposes that we find as a fact that the 1982               
          Unknown Deposits "are rents and land sale contract proceeds".               
          Petitioners have objected specifically to respondent's proposal             
          in a way that has aided us in making our finding as to amount of            
          1982 Unknown Deposits that constitute gross income to Walter.               
               Petitioners concede that $1,142.75 of the 1982 Unknown                 
          Deposits represents a commission check that is gross income to              
          Walter.  Petitioners concede that the 1982 Unknown Deposits                 
          represent rent and interest with respect to real property sales             
          (RP10142 and RP19547) in the amounts of $784 and $1,240 (total              
          $2,024) and that one-half, $1,012, is taxable to Walter (the                
          other half being taxable to Kosydar).  Petitioners concede that             
          the 1982 Unknown Deposits represent rental income in the amount             
          of $22,961, one-half of which, $11,481, is taxable to Walter (the           
          other half being taxable to Kosydar).  We accept petitioners'               
          concessions, and, based thereon, have found that the 1982 Unknown           
          Deposits constitute commission, interest, and rental income to              
          Walter in the amount of $13,636.6                                           
          6    On brief, petitioners challenge respondent's concession in             
          the Second Supplemental Stipulation of Facts, pars. 4 and 5, that           
          the interest income there described, in the amounts of $9,385 and           
          $8,704, should reduce the amount shown on Exhibit 201-GK for 1982           
          as unknown deposits.  This challenge would seem to be against               
          petitioners' interest.  Since we have not found total gross                 
          income from unknown deposits for 1982 in excess of 1982 Unknown             
          Deposits, we feel no pressure to resolve the conflict in the                
          parties' positions, and we do not.                                          
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