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through the disputed funds to TexGuarantyBk and should not be taxed
thereon.
With regard to 1987, evidence in the record indicates that
petitioner in 1987 paid funds to TexGuarantyBk that exceeded the
$22,149 that petitioner received from 2618 Inc to pay on the $275,000
TexGuarantyBk loan (see supra pp. 14-15). We conclude that the
amount of $22,149 in dispute for 1987 was received by petitioner on
behalf of 2618 Inc, was paid by petitioner to TexGuarantyBk, and
should not be treated as taxable income to petitioner.
With regard to the disputed $29,532 in deposits for 1988,
evidence indicates that petitioner in 1988 made total interest
payments of $12,251 to TexGuarantyBk on the $275,000 loan (see supra
p. 15). Other evidence indicates that petitioner did not pay to
TexGuarantyBk all of the funds that he received from 2618 Inc to pay
on this loan. We conclude that the amount of $17,281 or the
difference between the total $29,532 that petitioner received in 1988
from 2618 Inc with regard to interest due on the $275,000 loan and
the $12,251 in interest that petitioner paid to TexGuarantyBk should
be treated as taxable income to petitioner.
$12,826 in Deposits Relating to Payne & Potter -- 1987
Respondent argues that the $12,826 deposited into petitioner's
bank accounts (see supra p. 19) in connection with the disposition of
real estate held by Payne & Potter should be taxable to petitioner as
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