Bobby E. Syphrett and Janice D. Syphrett - Page 6

                                        - 6 -                                         

          Date/                                                                       
               Year 1989           Amount          Period                             
          Aug. 3                   $197,500    7/81 through 6/83                      
               Sept. 23            200,167    7/83 through 6/87                       
               Nov. 5              100,000    7/87 through 6/89                       
          Mr. Syphrett paid Intrastate the total amount of these invoices             
          through a series of checks dated August 28, September 1,                    
          September 5, September 7, October 30, and December 27, 1989.                
          Four of these checks were drawn on Mr. Syphrett's financial                 
          management account at Shearson Lehman Hutton (Shearson).  One of            
          these checks was drawn on petitioners' personal account at First            
          Interstate Bank of Texas, N.A. (First Bank).  The final check was           
          a bank check purchased by Mr. Syphrett at the First Gibraltar               
          Bank, FSB (First Gibraltar).  A summary of these checks is as               
          follows:                                                                    
           Date of the Check/                                                         
               Year 1989                Amount         Drawer                         
               Aug. 28                  $52,500        Shearson                       
               Sept. 1                  45,000         Shearson                       
               Sept. 5                  50,000         Shearson                       
               Sept. 7                  50,000         Shearson                       
               Oct. 30                  200,167        First Bank                     
               Dec. 27                  100,000        First Gibraltar                
                                       497,667                                       
               Intrastate reported its receipt of the $497,667 as gross               
          income on its tax return for its taxable year ended June 30,                
          1990.  Intrastate deducted on that return legal fees totaling               
          $419,765 and reported that it had no tax liability.  Intrastate's           








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011