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Walter Van Eck did not always deposit rents he
collected into the Bank Accounts. The amounts of rent
he did not deposit into any of the 24 Bank Accounts
during the years 1982 through 1986 [1985] years [sic]
were at least $1,164, $1,485.43, $552, and $3,000,
respectively.
Respondent's citations to the record in support of that finding
do not support any particular amounts of undeposited and
unreported rents for 1982 through 1985. Additional findings
proposed by respondent do support respondent's conclusion that
Walter did fail to deposit and report some rent for each of 1982
through 1985.
Petitioners object to respondent's proposed finding set out
above as follows:
Walter Van Eck deposited all rents received, even cash
rents (Tr. XIX). Very occasionally, he used some of
the cash before making the deposit, in which case he
replaced the cash with new cash, obtained by writing a
check to "Cash," so that the full rent deposit could be
made. (TR. XIX).
We cannot identify the indicated pages of the transcript and
conclude that petitioners have failed to rebut the conclusion to
be drawn from respondent's proposed finding that Walter failed to
deposit and report some rents. Petitioners have raised our
suspicion that not all of the amounts labeled as "Additional
Income" are rental income. The $3,000 amount shown for 1985 as
"19556 Payment" appears to be a payment with regard to a property
transaction that respondent concedes is not a taxable amount.
See Supplemental Stipulation of Facts paragraph 21 and Second
Supplemental Stipulation of Facts paragraph 33. Accordingly, we
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