- 27 -
Petitioners argue that $16,941 of the 1982 Unknown Deposits
represents loan proceeds, which, for that reason, are not
taxable. As to $15,000 of that amount, deposited to USB account
1348, petitioners proffer entries on two stipulated exhibits,
Exhibits 170-FN and 171-FO, both rental property listings,
prepared by Walter in December 1982 and in September 1983,
respectively, which show nothing more than certain estimated
mortgage balances. Petitioners offer nothing from the record
showing that $15,000 in loan proceeds constitutes part of the
1982 Unknown Deposits. As to the remaining $1,941, petitioners
have satisfied us that such amount does constitute the proceeds
of loans. The $15,000 item is a deposit to USB account 1348 that
petitioners have failed adequately to explain. Because USB
account 1348 was a joint account held by Walter with Kosydar, we
believe that only one-half of that amount ($7,500) constitutes an
item of gross income to Walter. Cf. Tokarski v. Commissioner,
87 T.C. 74 (1986). We have found accordingly.
Finally, petitioners argue that $500 for the 1982 Unknown
Deposits were deposited into an account of William Van Eck's and,
therefore, cannot be taxable to Walter. The account in question,
FIB account 5798, is in the name of William and Walter. We have
found that Walter made all the deposits and signed all checks
drawn on that account. William was not called to testify to
Walter's lack of authority over the account. From William's
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