-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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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