- 38 - 1987, Walter made all deposits to and signed all checks on USB 5155. Respondent originally classified certain deposits to the accounts set forth in the immediately preceding paragraph and to four additional accounts, FIB account 0053 (discussed supra paragraph 7.e.), OB account 9148 (discussed supra paragraph 5), OB account 4604 (discussed supra paragraph 7(e)) and an account identified only as "FIB-4941", as being deposits of unknown origin (the Original 1987 Unknown Deposits). The Original 1987 Unknown Deposits are as set forth in Exhibit 106-DB. The amount shown on Exhibit 201-GK for 1987 in the row labeled "Unknown" ($4,746.84) is the same as the 1987 Original Unknown Deposits and reflects that all of the Original 1987 Unknown Deposits are still in dispute as unknown deposits for 1987 (1987 Unknown Deposits). Of the 1987 Unknown Deposits, $4,497 constitutes an item of gross income to either Walter or Friedgard. OPINION Except with regard to OB account 4604 and the account that respondent has identified only as FIB-4941, we conclude that Walter had control and authority over all of the accounts listed under the heading "Unknown" on Exhibit 106-DB. We do not, however, conclude that he had any control and authority over FIB- 4941 or OB account 4604. Thus except with regard to the deposit to OB 4604 of $160 and the deposit to FIB-4941 of $89.81,Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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