- 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).
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