Ronald B. and Annette C. Talmage - Page 3




                                        - 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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