Robert E. Iles and Monica M. Iles - Page 14

                                        -14-                                          

               On October 30, 1981, two checks totaling $23,000, were drawn           
          on SSI’s Gradison Cash Reserves Account to third parties on                 
          petitioners’ behalf as performance bonuses for Robert.  The                 
          $23,000 was 1981 income to petitioners.                                     
               In 1982, 36 checks, totaling $198,850, were drawn on SSI’s             
          Southern Ohio Bank account to petitioners or to third parties on            
          petitioners’ behalf; the entire amount was 1982 income to                   
          petitioners.9                                                               
               In addition, in 1982, six checks, totaling $170,500, were              
          drawn on SSI’s Southern Ohio Bank account to Structured Shelters            
          Securities, Inc., hereinafter sometimes referred to as SSSI; they           
          constituted capital contributions to SSSI on behalf of Robert (52           
          percent), Monica (24 percent), and Doyle (24 percent).  Also in             
          1982, four checks, totaling $59,237.27, were drawn on that                  
          account to Finkelstein, Thompson, and Levenson, a Washington,               
          D.C., law firm; they, too, constituted capital contributions to             
          SSSI on behalf of Robert, Monica, and Doyle in the same                     


               8(...continued)                                                        
          process of adding the stipulated amounts.  We do not have any               
          reason to believe that petitioners were misled or in any way                
          prejudiced by respondent’s arithmetic error on brief.  As a                 
          result, we do not treat respondent’s proposed finding on this               
          point as an implicit concession of $9,000.                                  
               9    The parties’ stipulation lists 42 checks and 1 wire               
          transfer.  Respondent’s proposed finding omits six of the checks            
          and the one wire transfer.  We treat this as respondent’s                   
          implicit concession of the $23,108.30 total of these six checks             
          and the wire transfer.                                                      




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