- 29 -                                         
                    Account                       Amount                              
                         FIB 1550                 $6,494                              
                         FIB 5798                 1,450                               
                         USB 2221                  1,180                              
                         Total                    $9,124                              
               The amount shown on Exhibit 201-GK for 1983 in the row                 
          labeled "Unknown" ($658.44) reflects that portion of the Original           
          1983 Unknown Deposits still in dispute as unknown deposits for              
          1983 (1983 Unknown Deposits).  The 1983 Unknown Deposits                    
          constitute an item of gross income to Walter.                               
                                       OPINION                                        
               The 1983 Unknown Deposits are less than the Original 1983              
          Unknown Deposits because Walter has conceded that $8,466 of the             
          Original 1983 Unknown Deposits constitutes an item of gross                 
          income to him for 1983, and respondent has conceded that the                
          amount conceded by Walter no longer is a deposit of unknown                 
          origin for 1983.  We accept those concessions and so find.                  
          However, the parties have not told us out of which accounts the             
          conceded amount is deemed to have come.  That, however, is of no            
          consequence because we conclude that Walter owned the three                 
          accounts in question.  We have found that Walter made all the               
          deposits to and signed all checks drawn on FIB account 1550.  We            
          have found similarly with regard to FIB account 5798 (supra                 
          paragraph 7(a)).  We also have found that USB account 2221 was an           
          account maintained by Walter in his own name (supra paragraph 3).           
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