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account, $858 of refunds received by petitioner husband, and
$8,015 of other income.
Petitioners contend that respondent improperly reallocated
income from Americana to petitioners in disregard of section 482
by claiming that Americana was the alter ego of petitioner
husband. Similarly, petitioners argue that respondent improperly
9(...continued)
Checks written on escrow account:
Checks for personal expenses
and real estate $53,265.84
Checks to/for benefit of Mazzolas 46,387.00
Checks to Charlene Graham 1,287.00
Total checks: 100,939.84
Petitioners' basis in account:
Americana funds
Americana funds deposited to account $50,002.78
Payments to/for Mazzolas 46,387.00
3,615.78
Petitioners' funds
Installment income from real estate
sales $1,907.00
Rental income deposited to account 2,707.00
Transfers 3,110.00
Income from real estate sales 13,788.38
Funds from other sources 7,229.75
28,742.13
Total: 32,357.91
Funds for petitioners' benefit:
Rental income deposited to account $2,707.00
Checks written for petitioners'
benefit 53,265.80
Total: 55,972.80
Taxable income from account:
Funds for petitioners' benefit $55,972.80
Petitioners' basis in account 32,357.91
23,614.89
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