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Worldwide filed a Form 4876A, Election to be Treated as an
Interest Charge DISC.
A Form 5305, Individual Retirement Trust Account, was filed
on January 28, 1985, establishing Florida National Bank
(hereinafter Florida National) as trustee of IRA #1, and
petitioner as the grantor for whose benefit the IRA was
established. Under the terms of the IRA agreement, petitioner
retained the power to direct IRA #1's investments.
On the same day that the Form 5305 was filed, petitioner
directed Florida National to execute a subscription agreement for
2,500 shares of Worldwide original issue stock. The shares were
subsequently issued to IRA #1, which became the sole shareholder
of Worldwide.
For the taxable years 1985 to 1988, Swansons' Tool paid
commissions to Worldwide with respect to the sale by Swansons'
Tool of export property, as defined by section 993(c). In those
same years, petitioner, who had been named president of
Worldwide, directed, with Florida National's consent, that
Worldwide pay dividends to IRA #1.3 Commissions paid to
3
The following dividends were paid by Worldwide to IRA #1
during the taxable years 1986 through 1988:
Paid Date Fiscal Year Amount
4/8/86 12/31/86 $244,576
2/10/87 12/31/87 126,155
12/29/87 12/31/87 100,519
(continued...)
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Last modified: May 25, 2011