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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. We
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