- 201 - had unfettered access to the account; his name was on the account; and he directed the activities of the account. Similarly, in 1976 petitioner's FNCB account number 245925 earned interest in the amount of �27,466.39, the equivalent of $44,127.50. He owned the account, he was a signatory, and he had unfettered access to the account. Petitioner did not show that his accounts had any restriction or were in any way controlled by any person other than himself. He asserted through his testimony and the testimony of other witnesses that he considered the London accounts in his name to be those of Diesel Power. However, in 1974 and 1975 Diesel Power also had an FNCB account in London as well as FNCB accounts in Geneva, Switzerland. According to the testimony, all Diesel Power officers were signatories to the Diesel Power accounts. Petitioner's accounts were separate. We hold, pursuant to section 61, that the interest income on such accounts is taxable to petitioner. See Marcus v. Commissioner, T.C. Memo. 1992-234. In 1974, 1975, and 1976 the bank account or time deposits in the name of WHIP at the Barclays Bank Bahamas also earned interest in the respective amounts of $25,025, $29,338.94, and $16,998.06. As set forth in our findings of fact, WHIP was simply a repository for the receipt of commissions earned from Lockheed for petitioner's performance of services. Petitioner was the sole shareholder of WHIP and exercised full control overPage: Previous 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 207 208 209 210 Next
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