- 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 Next
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