Eloise Gaddy Joens - Page 4

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            Locksmith operated, and the corporation paid them $1,500 per                              
            month rent.  On the 1983 joint return, petitioner and Emmens                              
            reported rental income from Nelson Locksmith of $12,301.2                                 
                  Emmens sold Nelson Locksmith in January 1984.  On their 1984                        
            joint return, petitioner and Emmens reported a $20,753 gain                               
            attributable to the sale of the business and rental income of                             
            $2,243.                                                                                   
                  Petitioner was an authorized signatory on the bank accounts                         
            of Nelson Locksmith.  Additionally, petitioner occasionally wrote                         
            checks on this account for both business and personal purposes.                           
            Criminal Activity                                                                         
                  During the years in issue, Emmens was involved in narcotics                         
            trafficking.  He and various other individuals, including John                            
            Sydoriak (Sydoriak) and Vincent Kadyszewski (Kadyszewski),                                
            smuggled substantial amounts of marijuana and cocaine into the                            
            United States from the Bahamas.                                                           
                  The typical narcotics transaction would proceed as follows.                         
            Three boats would depart from Delray Beach, Florida (Delray                               
            Beach), and travel to Bimini, Bahamas (Bimini).  The boats were                           


                  2                                                                                   
                        The parties stipulated that for 1983 Nelson Locksmith                         
            paid petitioner and Emmens $1,500 per month, and that they                                
            reported $12,301 of rental income on their joint return.  We                              
            realize that the reported rental income for 1983 is less than                             
            $18,000 ($1,500 x 12).  The record is silent as to whether                                
            petitioner and Emmens received $1,500 each month for 12 months in                         
            1983.  Thus, we find that the $5,699 is a concession by                                   
            respondent in favor of petitioner.                                                        




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