- 31 - 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 accountPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
Last modified: May 25, 2011