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Head checking account number 351-00369 as the Indian Head per-
sonal checking account, (3) Indian Head savings account number
30-002583-0 as the Indian Head business savings account,
(4) Indian Head savings account number 015-000289-7 as the Indian
Head personal savings account, (5) Kennebunk checking account
number 33-802452 as the Kennebunk Olbres-Rohm business checking
account, (6) Kennebunk checking account number 56-868352 as the
Kennebunk business checking account, (7) Kennebunk savings
account number 20-004393 as the Kennebunk personal savings
account, and (8) Exeter checking account number 201-474-7300 as
the Seabrook Properties account.)
On April 22, 1988, petitioners closed the Indian Head
business savings account, which had a closing balance of
$464,409. On the same date, petitioners opened another business
savings account at Indian Head, account number 015-002290-3,
under the name "A.G. Olbres Design Consultants; Anthony or
Shirley Olbres" (1988 Indian Head business savings account) into
which they deposited $464,409.6
During 1988, petitioners also maintained the following
business bank accounts at Kennebunk:
6 The parties stipulated that the 1988 Indian Head business
savings account was a checking account. However, that stipula-
tion is contrary to the record in this case, which establishes,
and we have found, that that account is a savings account. We
may, and we shall in this instance, disregard stipulations
between the parties when the stipulations are clearly contrary to
the facts established by record. See Cal-Maine Foods, Inc. v.
Commissioner, 93 T.C. 181, 195 (1989).
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