- 37 - conclude that, with respect to such deposits ($857), Walter has failed to carry his burden of proving that such deposits do not constitute an unreported item of gross income for 1986. Tokarski v. Commissioner, supra. We have found accordingly. We sustain that part of respondent's determination of a deficiency for 1986 that is based on the 1986 Unknown Deposits to the extent we have found that the 1986 Unknown Deposits constitute gross income to Walter. f. 1987 FINDINGS OF FACT During 1987, a checking account was maintained in Oregon, at First Interstate Bank, in the name of R. Hodges, account number 564 0 01353 6 (FIB account 3536). Funds in that account were owned by Friedgard, and the account was used by her for personal purposes. During 1987, a checking account was maintained in Oregon, at Oregon Bank, in the name of R. Hodges, account number 18128730 (OB account 8730). Funds in that account were owned one-half by Walter and one-half by Friedgard, and the account was used by them for personal purposes. During 1987, a checking account was maintained in Oregon, at U.S. Bank, in the name of Friedgard V.B. Van Eck, account number 155-0812-109 (USB account 2109). USB 2109 was used by Walter as a business checking account. During a portion of 1987, a checking account was maintained in Oregon, at U.S. Bank, in the name of William F. Van Eck, account number 155-0045-155 (USB account 5155). DuringPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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