- 33 -
d. 1985
FINDINGS OF FACT
From March 1985 through at least 1986, a checking account
was maintained in Oregon, in Friedgard's name, at First
Interstate Bank, account number 564-0-04092 4 (FIB account 0924).
A portion of the funds deposited to FIB account 0924 were
transferred from FIB account 0058 (discussed in paragraph 7.b.,
supra). During a portion of 1985, Walter maintained a checking
account in Oregon, at U.S. Bank, account number 155-0501-843 (USB
account 1843).
Respondent originally classified certain deposits to FIB
account 0924, USB account 1843, and FIB account 0058, as being
deposits of unknown origin (the Original 1985 Unknown Deposits).
The Original 1985 Unknown Deposits are as follows:
Account Amount
FIB 0924 $370
USB 1843 350
FIB 0058 2,113
Total $2,833
The amount shown on Exhibit 201-GK for 1985 in the row
labeled "Unknown" ($808.75) reflects that portion of the Original
1985 Unknown Deposits still in dispute as unknown deposits for
1985 (1985 Unknown Deposits). Of the 1985 Unknown Deposits, $350
constitutes an item of gross income to Walter.
OPINION
The 1985 Unknown Deposits are less than the Original 1985
Unknown Deposits because Walter has conceded that $2,024 of the
Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 NextLast modified: May 25, 2011