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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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