- 39 -
in their Rule 155 calculation in order that the calculation
comports with respondent's concession.
For 1989, the unexplained bank deposits and respondent's
concession are as follows:
Source Amount
Cash deposits to accounts in United States $43,955
Check from USA Publishing 6,000
Check from Robert Wong 5,500
Check from Motomi 3,000
Check from Thomas Timbale 5,276
Deposits to Transamerica account 3,644
Check from Kanda A.G. 163
Check from Fusaku Aaoyaga 500
Total 68,038
Less amount conceded 16,238
Unexplained deposits in issue 61,800
1 In a stipulation of settled issues, respondent conceded that
the adjustment for "Unexplained deposits" in the notice of
deficiency for 1989 should be reduced $6,238, but respondent did
not identify the source or sources from which the conceded
amounts came. For purposes of the discussion below, we assume
that the source is either cash deposits to accounts in the United
States or deposits from unknown sources. Should our assumption,
be incorrect, the parties should make the appropriate correction
in their Rule 155 calculation in order that the calculation
comports with respondent's concession.
For 1990, the unexplained bank deposits are as follows:
Source Amount
Cash deposits to accounts in United States $39,000
Checks from Toraya Apartments 7,000
Check from Motomi 2,295
Check from Yashitaki Aoyagi 521
Check from California Physicians 3,357
Check from Nakamura 32,000
Deposits from unknown sources 30,761
Unexplained deposits in issue 114,934
For 1991, the unexplained bank deposits and petitioners'
concession are as follows:
Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 NextLast modified: May 25, 2011