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of his withdrawals from those accounts. Respondent further
contends that because of respondent's concessions in connection
with Ingersoll-Rand payments deposited to the Diesel Power Bank
of America account, petitioner's withdrawals from that account
constitute unreported income in any event.
Respondent asserts first on brief that petitioner withdrew
the following amounts from the Diesel Power Bank of America
account:
Year Amount
1973 $655,500.00
1974 531,633.48
1975 1,345,766.60
1976 665,000.00
In our findings of fact, we found that the evidence supported
withdrawals by petitioner from that account in amounts somewhat
smaller than respondent's assertion, namely:
Year Amount
1973 $655,500.00
1974 531,633.48
1975 601,652.03
1976 265,000.00
Subsequently, on brief respondent asserts that the amounts to be
considered income to petitioner because they were converted to
his personal use were as follows:
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