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deposits of $55,979. Respondent now concedes that the adjustment
for 1990 should be reduced to $42,506. The record is silent as
to the ground for the reduction. For 1991, respondent determined
that the Kudos had unreported income as shown by unexplained bank
deposits of $57,795. Respondent now concedes that $625 of the
unexplained deposits came from a nontaxable insurance payment and
that $4,132 came from nontaxable tax refunds. Thus, the amount
at issue for 1991 is $53,011.
The Kudos testified that they received some insurance
reimbursements and contributions from relatives for medical
expenses of their son Nicholas. However, the testimony was not
specific as to amounts, sources, or dates. Similarly, Motomi and
Scott testified that they periodically received gifts from
relatives in Japan for holidays and other celebrations. Motomi
also testified that she sometimes wrote checks to pay bills for
tenants of the apartments and restaurant employees who did not
have bank accounts, and they gave her the cash. She also paid
her parents' gardener when they traveled and was repaid in cash
when they returned. Again, the testimony was vague. The Court
is not required to accept unsubstantiated testimony. Geiger v.
Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159.
Nevertheless, we believe that the Kudos did receive some
amounts of this nature and that those amounts were deposited in
the bank. We thus find that the Kudos are entitled to reductions
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