-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. ThePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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