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petitioners have failed to carry their burden of proving that the
1987 Unknown Deposits do not constitute an unreported item of
gross income for 1987. Tokarski v. Commissioner, 87 T.C. 74
(1986). We have found accordingly. We sustain that part of
respondent's determination of a deficiency for 1987 that is based
on the 1987 Unknown Deposits to the extent we have found that the
1987 Unknown Deposits constitute gross income to Walter.
8. Nondeposited Amounts
FINDINGS OF FACT
During the years indicated, Walter received the following
amounts of rental income, which he did not deposit to any bank
account:
Year Amount
1982 $359.00
1983 1,485.43
1984 552.00
OPINION
On Exhibit 201-GK, under the heading "Additional Income", in
columns headed 1982 through 1985, are certain amounts that
respondent claims are income items that Walter received but did
not deposit in any bank account and failed to report as income.
Most of those amounts are labeled as rent. Three items (two for
1982 and one for 1985) are not labeled as rent. Respondent
supports her inclusion in gross income of the items under the
heading of "Additional Income" with the following proposed
finding of fact:
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