- 39 - 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: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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