- 41 -
Sierra Lakes properties (according to petitioners over $314,000
in 1982 plus an additional $524,803 in later years).13
Respondent contends that Yoshinori's testimony regarding any
nontaxable sources for the unexplained bank deposits was vague
and inconsistent. Respondent maintains that Yoshinori failed to
establish the amount the Takaos received between 1982 and 1987
from the alleged nontaxable sources. In addition, respondent
asserts that Yoshinori has not established that the Takaos did
not spend some or all of those funds or deposit them into their
bank accounts during those years.
Except to the extent explained below, we agree with
respondent that petitioners have not established a nontaxable
source for the unexplained bank deposits.
Cash From Japan
Petitioners testified that during the years in issue Akiko
brought back money from Japan, or received it in the mail from
her mother, as repayment on a loan Akiko made to her parents in
1959. We have found that Akiko received $3,600 during each of
13 Without deciding at this time how much the Takaos
actually received in installment sales payments from the Silver
Lake and Sierra Lakes properties between 1982 and 1987, it
appears that petitioners have miscalculated the total amount that
the Takaos received from those sales by counting twice the
$305,000 purportedly received in 1982. See table supra p. 18,
which reflects that a total of $524,803 was received between 1982
and 1987 from installment payments from the two properties,
including $305,000 received in 1982. The $524,803 total agrees
with the amounts reported on the Takaos' tax returns for 1982
through 1987 as payments received from the Silver Lake and Sierra
Lakes sales.
Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 NextLast modified: May 25, 2011