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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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