- 26 - 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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