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1982. SSI kept its books and records at SSI's headquarters,
where Robert had an office and worked on a daily basis. SSI
maintained a comprehensive tax library.
2. SSI's 1981 Undistributed Taxable Income
For its fiscal year ended July 31, 1981, SSI received, and
deposited into the Structured Shelters bank account, $436,400 in
gross income, consisting of $374,000 from Chartered
Representative Fees, $8,900 from setup fees, and $53,500 from
options. SSI's deductible expenses for this fiscal year total
$252,663.06. As a result, SSI's taxable income for this fiscal
year is $183,736.94. In addition, during this fiscal year SSI
made $75,498.55 in payments to or for the benefit of its
shareholders--$30,069.75 as to petitioners and $45,428.80 as to
Doyle. As a result, SSI's undistributed taxable income for its
1981 fiscal year is $108,238.39. Petitioners' 76-percent share
(Robert--52 percent, Monica--24 percent) of this amount is
$82,261.18.
SSI's fiscal 1981 tax return is discussed infra S. Tax
Returns.
3. SSI's 1982 Undistributed Taxable Income
For its fiscal year ended July 31, 1982, SSI had gross
income of $6,371,589. SSI's deductible expenses for this fiscal
year, plus SSI payments to or for the benefit of its
shareholders, total $4,958,269.90. As a result, SSI's
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