Zinovy Brodsky - Page 140




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          counts, are not taxable.                                                    
               On the record before us, we reject petitioner’s contention             
          that respondent’s bank deposits analysis for each of the years at           
          issue is inherently flawed.                                                 
               We turn now to the specific deposits that remain at issue              
          for each of the years 1991, 1992, and 1993, including any pay-              
          ments against the balances due on petitioner’s credit accounts              
          that remain at issue for each of those years.31  Petitioner                 
          contends that each of the deposits at issue is not taxable                  
          because each such deposit constitutes one of the following:                 
          (1) Personal loan; (2) business loan to UVW; (3) reimbursement              
          for certain expenses; (4) advance to purchase a personal item for           
          an acquaintance; (5) rental payment attributable to Konstantin              
          Reingatch (Mr. Reingatch); (6) income of, loan to, or reimburse-            
          ment with respect to MZ Trading; or (7) repayment of a loan.                
               Alleged Personal Loans                                                 
               Petitioner contends that, of the following total deposits,             
          including total payments against the balance due on petitioner’s            
          equity line account, the amounts set forth below represented                
          personal loans to him:                                                      



               31Petitioner did not raise as an issue in petitioner’s                 
          further trial memorandum, presented no evidence at trial and at             
          further trial, and makes no argument on brief as to certain                 
          amounts of unreported income determined for 1991 and 1993 that              
          petitioner placed in dispute in the petition and that respondent            
          has not conceded.  We conclude that petitioner has abandoned                
          contesting those amounts of unreported income.  See Rybak v.                
          Commissioner, 91 T.C. 524, 566 n.19 (1988).                                 




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