- 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.
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