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proportions. SSSI is discussed further infra at item Q. Also in
1982, a check in the amount of $18,716 was drawn on that account
to one Howard Blumenthal; it, too, constituted a capital
contribution to SSSI on behalf of Robert, Monica, and Doyle in
the same proportions.
In addition, in 1982, two checks, totaling $14,000, were
drawn on SSI's Southern Ohio Bank account to Structured Shelters
Financial Management, Inc., hereinafter sometimes referred to as
SSFMI; they, too, constituted capital contributions to SSFMI on
behalf of Robert (52 percent), Monica (24 percent), and Doyle (24
percent). SSFMI is discussed further infra at item R.
As a result, petitioners had 1982 income in the amount of
$199,464.49 on account of SSI's 1982 payments of capital
contributions to SSSI and SSFMI on petitioners' behalf.
1. SSI's Financial Books and Records
SSI used an accrual method of accounting and had a fiscal
year ending July 31. SSI prepared and maintained a
contemporaneous balance sheet, a general ledger, a check
disbursement schedule, a journal, and profit and loss statements
during its fiscal years 1981 and 1982. SSI prepared and
maintained a contemporaneous cash receipts journal for the period
September 19, 1980, through July 31, 1982. SSI prepared and
maintained contemporaneous profit and loss statements and journal
entries related to bank statement debits during its fiscal year
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