Stephen P. and Jutta A. Maranto - Page 5

                                        - 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