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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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