- 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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