- 36 - Unknown Deposits). Of the 1986 Unknown Deposits, $857 constitutes an item of gross income to Walter. OPINION The 1986 Unknown Deposits are less than the Original 1986 Unknown Deposits because Walter has conceded that $147.79 of the Original 1986 Unknown Deposits constitutes an item of gross income to him for 1986, and respondent has conceded that the amount conceded by Walter no longer is a deposit of unknown origin for 1986. 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 FIB account 0053, as we did for the predecessor account, FIB account 1550 (see discussion supra paragraph 7.b.). We do not, however, conclude that he had any control and authority over OB account 4604, the Hodges account. As was true for 1984 and 1985, Walter has the burden of proving the extent to which the $147.79 that he conceded is an item of gross income reduces the Original 1986 Unknown Deposits to FIB account 0053. Walter has failed to prove any such reduction. Thus, we find that the such conceded amount ($147.79) reduces the Original 1986 Unknown Deposits to OB account 4604 to the extent thereof, $835, and, since nothing remains, nothing reduces the Original 1986 Unknown Deposits to FIB account 0053. Accordingly, the full $857 of Original 1986 Unknown Deposits to FIB account 0053 remains as 1986 Unknown Deposits to that account. WePage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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