- 5 - Mrs. Maranto was employed as a Deputy Clerk for the County of San Diego during this time, and her gross salary for 1991 was $19,708.05. Petitioners' Educational and Health Care Expenses In May 1991, petitioners paid $300 to National Note, Inc., for the Behle Real Estate Education Correspondence Course, a home-study course on investments in real estate trust deeds. Petitioners received $300 from the Herkeios Group as reimbursement for educational materials, which was deposited into their joint checking account at Grossmont Bank. On September 25, 1991, petitioners received $1,688.92 from the Herkeios Group as reimbursements for health expenses, which was deposited into their joint checking account at Grossmont Bank. Proceedings in the U.S. District Court for the Southern District of California On August 24, 1994, respondent issued a third-party recordkeeper3 summons to International Savings Bank with respect to petitioners' 1991 Federal income tax return. On September 13, 1994, petitioners filed a petition with the U.S. District Court 3Sec. 7609(a)(3)(A) defines a "third-party recordkeeper" to include "any mutual savings bank, cooperative bank, domestic building and loan association, or other savings institution chartered and supervised as a savings and loan".Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011