-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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