James M. Rankin and Shirley Rankin - Page 8

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          Rather, the deductions claimed for forfeitures or summary                   
          judgments represented only those amounts paid from other sources.           
          Pursuant to that practice, petitioner did not intend to report as           
          income the balances remaining in the accounts upon termination of           
          the agreement and satisfaction of all liabilities secured by                
          them.                                                                       
               As of January 1, 1988, Associated maintained seven separate            
          BUF accounts for petitioner.  As of that date, the surety's                 
          ledgers for petitioner's BUF accounts reflected the following               
          balances:                                                                   
                    Account                   Balance                                 
               Rankin-Johnson                $20,075.58                               
               Rankin-Vallejo                10,986.80                                
               James M. Rankin (Ann)         71,420.02                                
               James M. Rankin-Hayward       5,360.87                                 
               James M. Rankin #2            92,180.28                                
               Rankin-Carter                 10,294.23                                
               Rankin-Williams               1,803.70                                 
               The opening balance of petitioner's BUF accounts as of that            
          date shown in the surety's ledgers was $212,122 (rounded).  The             
          amount of accumulated interest on the BUF accounts as of January            
          1, 1988, shown in the surety's ledgers was $65,623 (rounded).               
          For purposes of calculating the adjustment of petitioners' income           
          to be made pursuant to section 481(a), the opening balance of the           
          BUF accounts as of January 1, 1988, is considered to be $146,499            
          (rounded), which does not include the amount of $65,623 (rounded)           
          that represents interest accumulated on the BUF accounts as of              
          that date.                                                                  




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