Shigenori Kudo and Motomi Kudo, et al. - Page 73

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          accounts of the Takaos for 1988 through 1991, (2) certain cash              
          purchases by the Takaos in 1988 and 1989, and (3) unexplained               
          cash deposits into the bank accounts of the Kudos for 1990 and              
          1991.  Respondent concedes that cash deposits into the bank                 
          accounts of the Kudos in 1990 and 1991 in the amounts of $42,506            
          and $46,871 do not constitute gross receipts of Toraya for those            
          years.  Additionally, we have decided, as discussed above in the            
          section relating to unreported income of the Takaos, that $3,600            
          per year of the unexplained cash deposits by the Takaos came from           
          the repayment of a loan by Akiko's parents and, thus, was not               
          taxable to the Takaos.  We also decided, as discussed above, that           
          during 1989 Akiko used $20,000 of a cash hoard accumulated before           
          1988 to purchase a car for Yoshinori and, thus, that amount also            
          was not taxable to the Takaos.  It follows that those amounts are           
          not  unreported receipts of Toraya.  Accordingly, unreported                
          income of Toraya remaining in issue is as follows:                          
                                   Unreported income                                  
          Per the notices   Less respondent's  Less amounts from     Amount           
          Year      of deficiency      concessions      nontaxable sources   in issue 
          1988         $94,500             --                 $3,600          $90,900 
          1989         102,275             --                 23,600           78,675 
          1990          81,506           $42,506               3,600           35,400 
          1991          58,271            46,871               3,600            7,800 
                                                                                     
               Petitioners deny that Toraya had any unreported income for             
          the years in issue.  Petitioners contend that the unexplained               
          deposits into the Takaos' bank accounts did not come from the               
          restaurants owned and operated by them or Toraya.  Petitioners              






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