- 102 - The 1974 interest income earned on the London FNCB account of $38,055.71 and dividends from Crown Life of $436.50 are includable in petitioner's gross income. The 1975 interest income earned on the London FNCB account of $43,641.69 and dividends from Crown Life of $445.30 are includable in petitioner's gross income. The 1976 interest income earned on the London FNCB account of �27,466.39 and dividends from Crown Life of $459.05 are includable in petitioner's gross income. IV. Interest Income--WHIP Account at Barclays Bank Bahamas During 1974, 1975, and 1976 interest was earned on bank accounts or time deposits in the name of WHIP at the Barclays Bank in Freeport, Bahamas, in the respective amounts of $25,025, $29,338.94, and $16,998.06. Petitioner, through his attorney, formed WHIP. Petitioner was the sole shareholder of WHIP. Named shareholders were nominees. In 1975 petitioner paid $628.30 to Price Waterhouse for account services to WHIP and claimed a deduction on his tax return for this amount. WHIP's banking and other business activities were handled by petitioner and CTC employees. Petitioner was sole signatory over WHIP's bank account at Barclays Bank Bahamas. From the time of WHIP's formation in 1969 through at least 1978, WHIP did not carry on any independentPage: Previous 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 Next
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