- 81 - 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).Page: Previous 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 Next
Last modified: May 25, 2011