- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011