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Original 1985 Deposits constitutes an item of gross income to him
for 1985, and respondent has conceded that the amount conceded by
Walter no longer is a deposit of unknown origin for 1985. 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 that Walter had control and authority
over USB account 1843 that amounted to ownership of that account.
We do not, however, conclude that he had any control and
authority over FIB accounts 0058 and 0924, the accounts in
Friedgard's name. As was true for 1984, Walter has the burden of
proving the extent to which the $2,024 that he conceded is an
item of gross income reduces the Original 1985 Unknown Deposits
to USB account 1843. Walter has failed to prove any such
reduction. Thus, we find that the such conceded amount ($2,024)
reduces the Original 1985 Unknown Deposits to FIB accounts 0058
and 0924 to the extent thereof, $2,483 ($2,483 = $370 + 2,113),
and, since nothing remains, nothing reduces the Original 1985
Unknown Deposits to USB account 1843. Accordingly, the full $350
of Original 1985 Unknown Deposits to USB account 1843 remains as
1985 Unknown Deposits to that account. We conclude that, with
respect to such deposits ($350), Walter has failed to carry his
burden of proving that these deposits do not constitute an
unreported item of gross income for 1985. Tokarski v.
Commissioner, 87 T.C. 74 (1986). We sustain that part of
respondent's determination of a deficiency for 1985 that is based
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