J.J. Zand - Page 13

                                        - 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 independent                







Page:  Previous  92  93  94  95  96  97  98  99  100  101  102  103  104  105  106  107  108  109  110  111  Next

Last modified: May 25, 2011