- 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
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