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ledger card. We sustain respondent’s determination that the
$140,000 deposit represents taxable income to petitioner.
5. Other Deposits
FINDINGS OF FACT
On May 6, 1986, petitioner deposited $300 into his Freedom
account. On August 1, 1986, a deposit of $9,038.47 was made to
Mr. Miles’s law firm’s trust account. On October 10, 1986, $300
was deposited into Mr. Miles’s law firm’s trust account for
petitioner. Respondent determined that those deposits were
taxable as income to petitioner.
OPINION
Petitioner does not discuss on brief the deposit of $300 on
May 6, 1986. We find that he received that item as income.
In respondent’s reply brief, he concedes that the deposit of
$9,038.47 on August 1, 1986, to Mr. Miles’s law firm’s trust
account was not income to petitioner.
Petitioner does not discuss on brief the deposit of $300 on
October 10, 1986. We find that he received that item as income.
F. Deductions Claimed by Petitioner
1. Schedule C Real Estate Business Deductions
FINDINGS OF FACT
Petitioner claimed deductions on the Schedules C for his
real estate business on his returns for 1985 through 1988. Those
deductions were claimed on the basis of the spreadsheets that
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