-17-
undistributed taxable income for its 1982 fiscal year is
$1,413,319.10. Petitioners' 76-percent share (Robert--52
percent, Monica--24 percent) of this amount is $1,074,122.52.
D. Free Enterprise Trust
SSI marketed some tax shelters under the name "Free
Enterprise Trust", hereinafter sometimes referred to as the FE
Trust. Petitioners, as trustees, maintained the FE Trust's
Southern Ohio Bank account, which was used predominantly by SSI
clients as a depository for investments. Amounts disbursed from
the account were used mainly to buy tax shelter investments for
SSI's clients. During the period December 1, 1981, through
February 24, 1982, a total of $8,827,197.09 was deposited into
the FE Trust's Southern Ohio Bank account, and $8,564,090.55 was
disbursed from this account. The FE Trust did not file a tax
return.
A $176,500 withdrawal from this account is discussed infra
under I. Lincoln American Securities.
E. Riago Trust
In 1980, Robert suggested to Monica that petitioners
transfer all of their assets to a trust. On May 4, 1981,
petitioners, as grantors, executed a Declaration of Trust
establishing Riago Revocable Trust, hereinafter sometimes
referred to as the Riago Trust. Robert was the principal author
of the Declaration of Trust establishing the Riago Trust. The
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