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Michoff, Jr., made deposits to his World Savings Bank
accounts of $5,207 which is in issue in the 1989 tax year. These
are not the total amount of deposits made into these accounts in
the 1989 tax year.
Respondent contends that the source of the $39,197 in
payments and the $5,207 in deposits has not been identified by
petitioners. In response to respondent's proposed findings of
fact on these issues, Michoff, Jr., states: “Objection.
$5,207.00 receipts from limousine business reported on
Petitioner's Schedule 'C' and included in $6,000 gross receipts.”
Because this is the only objection to respondent's proposed
findings of fact regarding those amounts, we consider the $39,197
expenditure to have been conceded to be unreported income.9
Additionally, Michoff, Jr., provided no evidence that the $5,207
came from previously taxed income.
Michoff, Jr., made deposits into his Placer savings account
in the amount of $1,528 which is in issue in the 1989 tax year.
This amount is not the total amount deposited into this account
in the 1989 tax year. Of this amount, Michoff, Jr., contends
that $1,098 came from Kimberly Michoff's salary. The only proof
of this source is the vague, unsubstantiated testimony of
Michoff, Jr. Michoff, Jr., contends that most of the remaining
9 We rely extensively on petitioners' responses to
respondent's proposed findings of fact. On brief, petitioners
state: “Petitioners have extensively explained their 'unreported
income' in the Objection to Respondent's Requested Findings of
Fact and, therefore, it is unnecessary to repeat them here.”
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