John M. and Rita K. Monahan - Page 32

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          controlling facts would be dismissed in the same manner that                
          similar contentions of petitioners regarding the Aldergrove issue           
          were dismissed, see supra sec. II.C.4.c.                                    
               In conclusion, petitioners are precluded from denying that,            
          on February 26, 1987, and December 22, 1988, petitioner                     
          controlled Aldergrove partnership matters and benefited from and            
          controlled the funds held by Aldergrove.                                    
                    f.  Are the 1991 Interest Payments Taxable to                     
                    Petitioners?                                                      
               Promissory notes in evidence indicate that petitioner loaned           
          the following amounts to Chestnut Grove and Group M, and we so              
          find:                                                                       



          Date                         Maker                 Amount                   
          March 1, 1987            Chestnut Grove           $23,382                   
          March 1, 1987            Group M                  176,618                   
          March 1, 1988            Group M                  110,000                   
          January 19, 1989         Group M                  200,000                   
          Petitioners present numerous documents and other evidence to                
          explain the fate of the first three of those notes and to support           
          their assertion that the Yakima interest payments represent                 
          interest paid to Mr. Bell.  The findings, however, that, on                 
          February 26, 1987, and December 22, 1988, petitioner controlled             
          Aldergrove partnership matters and benefited from and controlled            







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