- 32 - 1550 and USB account 2221 that amounted to ownership of those accounts. We do not, however, conclude that he had any control and authority over FIB account 0058, Friedgard's personal account. Walter has the burden of proving the extent to which the $4,917 that he conceded is an item of gross income reduces the Original 1984 Unknown Deposits to FIB account 1550 and USB account 2221. Walter has failed to prove any such reduction. Thus, we find that the such conceded amount ($4,917) reduces the Original 1984 Unknown Deposits to FIB account 0058 to the extent thereof, $668, and only the remainder, $4,249 ($4,249 = $4,917 - $668), reduces the Original 1984 Unknown Deposits to FIB account 1550 and USB account 2221. The Original 1984 Unknown Deposits to those two accounts totaled $8,838 ($8,838 = $7,738 + $1,100). After taking into account the conceded amount allocated thereto, the 1984 Unknown Deposits remaining in those accounts is $4,589 ($4,589 = $8,838 - $4,249). We conclude that, with respect to such deposits ($4,589), Walter has failed to carry his burden of proving that these deposits do not constitute an unreported item of gross income for 1984. Tokarski v. Commissioner, supra. We have found accordingly. We sustain that part of respondent's determination of a deficiency for 1984 that is based on the 1984 Unknown Deposits to the extent we have found that the 1984 Unknown Deposits constitute gross income to Walter.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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