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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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