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Accordingly, petitioners have failed to prove Akiko's cash hoard
constituted a nontaxable source for the unexplained bank
deposits.
Specific Checks
Petitioners suggest in their brief that deposits from Motomi
made during 1988, 1989, and 1990 were reimbursements for money
Akiko gave her for purchases, that deposits from U.S.A.
Publishing made in 1988 and 1989 were loan repayments made on a
loan the Takaos made to that entity in 1982, that the deposit
from California Physicians in 1990 was a refund for a medical
payment, and that the deposit from Alameda County in 1991 was
some type of refund. This Court does not consider statements in
brief as proof. Rule 143(b); Niedringhaus v. Commissioner, 99
T.C. 202, 214 n.7 (1992); Viehweg v. Commissioner, 90 T.C. 1248,
1255 (1988); Evans v. Commissioner, 48 T.C. 704, 709 (1967),
affd. per curiam 413 F.2d 1047 (9th Cir. 1969). Petitioners
presented no evidence at trial in support of their contentions
that the deposits were made for the reasons asserted.
Accordingly, petitioners have not established that those deposits
came from a nontaxable source.
Petitioners suggest on brief that the checks from Toraya
Apartments deposited in 1988, 1990, and 1991 were rental income
that was reported already on the Takaos' returns for those years.
The record shows that Toraya Apartments was a partnership of
which Nakamura was the managing general partner, and that the
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