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he did not remember the terms of these loans. He further
testified that he and Michoff, Jr., did not document these loans.
Michoff, Jr., later testified that they did document the various
loans. Furthermore, until 1995, there is no evidence that any of
the amounts were ever repaid. Michoff, Jr., has failed to prove
that any of the funds came from loans.
Michoff, Jr., made deposits into his Downey savings account
in the amount of $3,334 which is in issue in the 1986 tax year.
This is not the total amount of deposits in this account in the
1986 tax year. This amount does not include $1,000 that was
identified as a transfer.
Michoff, Jr., made a deposit of $3,686 into Kimberly
Michoff's Great Western account in the 1986 tax year. This
amount is not the total amount deposited into this account in the
1986 tax year by Michoff, Jr. Michoff, Jr., conceded on brief
that this deposit has not been identified as coming from a
nontaxable source.
Michoff, Jr., made deposits into his Pacific Valley Bank
account in the amount of $220 in the 1986 tax year.
In the 1987 tax year, Michoff, Jr., made payments to the
Knights in the amount of $76,195 toward the purchase of the
Knight property. Of this amount, respondent contends that
$15,682 cannot be traced to previously taxed or nontaxable
sources. Of the $15,682, Michoff, Jr., admits that $622 is from
unknown sources.
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