- 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).Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011