Walter Van Eck and Friedgard Van Eck - Page 31

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               Respondent originally classified certain deposits to FIB               
          account 0058 and to two additional accounts, FIB account 1550               
          (discussed paragraph 7.b., supra) and USB account 2221 (discussed           
          paragraph 3, supra), as being deposits of unknown origin (the               
          Original 1984 Unknown Deposits).  The Original 1984 Unknown                 
          Deposits are as follows:                                                    
                              Account             Amount                              
                              FIB 0058            $668                                
                             FIB 1550            7,738                               
                             USB 2221             1,100                              
                            Total                 $9,506                              
               The amount shown on Exhibit 201-GK for 1984 in the row                 
          labeled "Unknown" ($4,588.25) reflects that portion of the                  
          Original 1984 Unknown Deposits still in dispute as unknown                  
          deposits for 1984 (1984 Unknown Deposits).  Of the 1984 Unknown             
          Deposits, $4,589 constitutes an item of gross income to Walter.             
                                       OPINION                                        
               The 1984 Unknown Deposits are less than the Original 1984              
          Unknown Deposits because Walter has conceded that $4,917 of the             
          Original 1984 Unknown Deposits constitutes an item of gross                 
          income to him for 1984, and respondent has conceded that the                
          amount conceded by Walter no longer is a deposit of unknown                 
          origin for 1984.  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.  We conclude, as we did             
          for 1983, that Walter had control and authority over FIB account            






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