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to UVW Department rather than merely to UVW.
2The record does not disclose whether account No. 1249-9-01004 was a
checking, a savings, or some other type of account.
3Account No. 1396118294 was a revolving loan account which had a credit
limit of $22,000.
4The record does not disclose whether account No. 4/003-4971259 was a
checking, a savings, or some other type of account.
5The parties stipulated that account No. 4019-0121-0086-4798 was a
Master Card account that petitioner maintained during the years indicated.
That stipulation is clearly contrary to the facts that we have found are
established by the record, and we may, and we shall, disregard it. See Cal-
Maine Foods, Inc. v. Commissioner, 93 T.C. 181, 195 (1989). The record
establishes, and we have found, that account No. 4019-0121-0086-4798 was a
Visa account in the names of both petitioner and Ms. Brodsky.
(For convenience, we shall refer (1) to Bank of America account
No. 11801-10725 as petitioner’s UVW account, (2) to Bank of
America account No. 1396118294 as petitioner’s equity line
account, (3) collectively to petitioner’s equity line account,
petitioner’s Bank of America automobile loan account No. 1389-6-
56940, and all credit card accounts listed above as petitioner’s
credit accounts, (4) collectively to all banking, checking, and
savings accounts listed above as petitioner’s bank accounts, and
(5) collectively to all the accounts listed above as petitioner’s
accounts.)
Certain Activity With Respect to Petitioner’s Accounts
During the years at issue, the total amounts shown below
were deposited into petitioner’s bank accounts, including peti-
tioner’s UVW account, or were deposited into petitioner’s credit
accounts, including petitioner’s equity line account, i.e., were
paid against the balances due on such credit accounts:
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