- 73 - 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. PetitionersPage: Previous 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 Next
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