-32-
The second bank deposits analysis identifies the following
amounts as deposits of proceeds from:
Rents $26,617
Interest 2,504
Dividends 119
Taxi checks 7,764
The second analysis does not correctly take into account the
amounts reported by petitioners.
We conclude that petitioners have unexplained deposits as
follows:
Unexplained deposits as determined by respondent $79,147
Less: Income reported by petitioners but not
accounted for by respondent:
Rent (32,338)
Interest ( 855)
Dividends ( 758)
Taxi (11,736)
Adjusted unexplained deposits $33,460
Petitioners have failed to provide any other evidence that the
unexplained deposits, as determined above, do not constitute
unreported income. Thus, respondent's determination, as adjusted
above, that petitioners had unreported income will be sustained.
Unreported Income--Like-Kind Exchange
Respondent initially argued that petitioners' transfer of
$80,000 from the 14 Siros escrow to Shumin for the downpayment on
29 Hastings and their provision of other amounts necessary for
Shumin's purchase of 29 Hastings somehow alter the exchange.
Respondent has not argued that petitioners were not repaid for
the advances to Shumin.
That petitioners provided funds for Shumin's purchase of
29 Hastings does not change the treatment of the exchange of
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