- 3 - After concessions,2 the issues for decision are: (1) Whether certain wire transfers from Hong Kong to the United States in 1998, 1999, 2000, 2001, and 2002 constitute nontaxable loans; (2) whether Ronald B. Talmage (petitioner) failed to report unexplained bank deposits in 1998, 2001, and 2002 of $36,263, $13,454, and $42,553 respectively; and (3) whether petitioner failed to report gains from the sale of rental property in Vancouver, Washington, and a vacation home in Black Butte, Oregon, for 1998; (4) whether petitioner is entitled to 2 Respondent concedes that the gains from the sale of the Vancouver, Washington, and Black Butte, Oregon, properties in 1998 were $31,231 and $120,606, respectively. Respondent concedes that the bank deposit of $265,269 on Aug. 24, 1998, to the Talmages’ account No. * * * 3034 with the US Bank comprised the proceeds from the sale of the Black Butte, Oregon, property. As a result, only $36,263 of the unexplained bank deposits for 1998 is in dispute. Respondent concedes reductions for the wire transfers from New Century Properties, Ltd. (NCPL), to A.C. Schommer & Sons, Inc. (SSI), in 1999 and 2000 of $10,000 and $246,057, respectively. Respondent concedes a reduction for the wire transfers from NCPL to petitioner for child support in 2002 of $7,320. Petitioner concedes FICA tax on unreported wages for 1999, 2000, and 2001 of $3,773, $5,942, and $5,191, respectively. Petitioner concedes that losses on Schedules F, Profit or Loss From Farming, for 2000, 2001, and 2002 of $31,239, $9,706, and $22,875, respectively, were for activities not engaged in for profit pursuant to sec. 183. Petitioner concedes that the assessment of a deficiency for 1998 is not barred under sec. 6501(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008