Walter Van Eck and Friedgard Van Eck - Page 39

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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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