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The parties have stipulated that during 1992, $3,400 in dividends
was paid on stock registered in Landtrak’s name.
The notice to Mr. Comey for 1992 included in Mr. Comey’s
income $2,919 of the $3,400 in dividends paid on stock registered
in Landtrak’s name. Respondent is aware of the discrepancy
between the $2,919 in dividends determined in the notice and the
$3,400 in dividends described in the stipulation, but has decided
not to seek an increased deficiency.
In light of the parties’ stipulation and respondent’s
decision, we find that $2,919 of dividends was paid in 1992 on
stock registered in Landtrak’s name.
Mr. Comey’s only argument is that these dividends are
Landtrak’s income, because Landtrak owned the stock registered in
its name.
Sales Proceeds Received by Landtrak in 1992
In August 1992, shares of stock in 15 companies, which had
been registered in Mr. Comey’s name, but were recently
reregistered in Landtrak’s name, were transferred to an account
maintained with PaineWebber and held in Landtrak’s name. On
August 19, 1992, the stock in the PaineWebber account was sold
for aggregate proceeds of $591,438.
On August 21, 1992, a PaineWebber check for the proceeds was
deposited in a checking account maintained in Landtrak’s name
with the M&I Bank of Menomonee Falls, Wisconsin. On August 26 or
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