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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 over
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