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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
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Last modified: May 25, 2011