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listed as secretary of Americana on its account. Petitioner
husband signed petitioner wife's name on the signature card for
the Americana account. Petitioner husband used his Social
Security number on the BRT and Canta business accounts for the
years in issue.
Petitioner husband deposited the following amounts in 1987:
Account Type of Income Amount
Petitioner wife commissions $3,534.74
Petitioner wife other 4,500.00
BRT commissions 34,103.96
BRT refunds 724.31
BRT other 3,052.00
Canta commissions 680.00
Canta refunds 133.95
Canta other 462.50
Americana other1 11,502.38
Petitioner husband had $32,598.70 of commissions,2 $858.26
of refund income,3 and $19,517 of other income in 1987.
Petitioners reported income of $29,522 from petitioner husband's
real estate activities for 1987.
Petitioner husband deposited the following amounts in the
Earl Kiem Bell/Shores escrow account in 1987:
1 Americana deposited in its checking account $11,502.38,
reflecting the net proceeds from cashing CD's of $80,002.38, and
replacing them with CD's of $68,500.
2 Petitioner husband deposited $38,318.70 in commissions;
however, we subtracted $4,875 of land contract payments and $845
of transfers between bank accounts in figuring his commission
income for 1987.
3 Petitioner husband received refunds of certain business
expenses, such as insurance and utilities, that he deposited in
his various accounts.
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