- 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'sPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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