- 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). During
Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 NextLast modified: May 25, 2011