- 19 -- 19 - Taking account of the parties' concessions and the errors that we found in certain stipulations and in the briefs, on the record before us, we find that the amounts of petitioners' un- reported income for 1989 and 1990 that remain in dispute are $174,030.35 and $121,061.97, respectively, calculated as follows: 1989 1990 Deposits treated as unreported income in the notice . . . . . . . $817,214.29 $319,904.41 Less concessions by respondent . . 640,684.049 218,152.6410 Less concession by petitioners . . 2,500.0011 -- Deposits in the notice that remain in dispute after taking account of concessions by the parties . . . . 174,030.35 101,751.77 Amount of the Kabeiseman loan proceeds deposited during 1989 and not repaid as of Dec. 31, 1990, that respondent contends is income from the discharge of indebtedness -- 19,310.20 Amounts of unreported income remaining in dispute . . . . . . . 174,030.35 121,061.97 9 Respondent's concessions for 1989 consist of the following deposits into petitioners' accounts during that year: (1) De- posits of $481,051.62 disbursed from petitioners' accounts as payments to, or on behalf of, K & H, (2) deposits of $29,000 of the Kabeiseman loan proceeds, (3) a deposit of $17,000 of the proceeds of the sale of a promissory note to Mr. Kabeiseman, and (4) other deposits of various items totaling $113,632.42. 10 Respondent's concessions for 1990 consist of the following deposits into petitioners' accounts during that year: (1) De- posits of $56,155.40 disbursed from petitioners' accounts as payments to, or on behalf of, K & H, (2) a deposit of $22,500 of the proceeds of the sale of property known as "Dairy Creek", in which petitioners had a basis of $22,649.60, and (3) other deposits of various items totaling $139,497.24. 11 See supra note 5.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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