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Deposits of K & H's Construction Loan
Proceeds, Checking Account Funds, and
Credit Line Funds and Ms. Velilla's
Construction Loan Proceeds and
Checking Account Funds
The parties agree that (1) during 1989, petitioner deposited
into one of petitioners' accounts K & H's funds totaling
$544,323.97; (2) during 1989, petitioner deposited into one of
petitioners' accounts Ms. Velilla's construction loan proceeds
totaling $27,394; (3) during 1990, petitioner deposited into two
of petitioners' accounts K & H's funds totaling $81,570.46;
(4) during 1990, petitioner deposited into one of petitioners'
accounts Ms. Velilla's funds totaling $34,753; (5) petitioners'
1989 and 1990 returns did not include any portion of the forego-
ing deposits as income; (6) during 1989 and 1990, petitioners
made certain payments from their accounts to, or on behalf of, K
& H; and (7) to the extent that during 1989 and 1990 petitioners
made payments to, or on behalf of, K & H or Ms. Velilla, the
aggregate amount of such payments during each such year should
reduce the aggregate amount of the foregoing deposits during each
such year. The only disagreements between the parties with
respect to the deposits during 1989 and 1990 of K & H's funds and
Ms. Velilla's funds are (1) whether the aggregate amount of those
deposits during each such year exceeded the aggregate amount of
17(...continued)
outstanding balances of the Kabeiseman loans would remain the
same regardless who bears the burden of proof with respect to
that argument.
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