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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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