Shigenori Kudo and Motomi Kudo, et al. - Page 41

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          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.                                                                




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