- 13 - only one-half of the unexplained deposits constitutes an item of gross income to Michael Friscia. See Van Eck v. Commissioner, T.C. Memo. 1995-570. Accordingly, $2,785 of the deposits into these accounts represents income to Michael Friscia in 1995. 2. The 533 Account Michael Friscia deposited $20,760 into the 533 account in 1995. Michael Friscia concedes that this entire amount represents wages he earned from Friscia Construction in 1995 and is reportable by him as income. 3. The 522 Account Michael Friscia deposited $52,199 into the 522 account in 1995. Respondent concedes that Michael Friscia made $17,949 in nontaxable transfers into this account. Michael Friscia has established that the following additional deposits into the 522 account are not taxable to him: (i) $12,692 in wages earned by Michelle Friscia, and (ii) $3,000 in nontaxable proceeds from the sale of a truck inherited from his father. Michael Friscia concedes that he deposited $18,345 in proceeds from his Mik Mic business and wages from Friscia Corporation into the account. One-half of the remaining $213 (or $107) in unexplained deposits is taxable to Michael Friscia because of his joint interest in the account. See id. Accordingly, $18,452 of the deposits into the 522 account represents income to Michael Friscia for 1995.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011