-23-
In 1980, Monica wrote four checks totaling $100,000 to
Robert from the Cocoa Trust Escrow Fund.10 One of these checks,
for $90,000, is discussed infra at item H. All $100,000 was 1980
income to Robert.
In 1981, seven checks totaling $29,300 were written to
Robert from the Cocoa Trusts Escrow Fund.11 All $29,300 was 1981
income to Robert.
H. Robert Iles, et al.
In 1978, Robert and Robert C. McCormick, hereinafter
sometimes referred to as McCormick, formed the partnership Robert
Iles, et al. Robert Iles, et al., was a "computer company",
providing data processing and other services. Robert had a 65-
percent interest in Robert Iles, et al., and was the
partnership's managing partner. McCormick had a 35-percent
interest in Robert Iles, et al. Both partners contributed
capital and both partners were authorized signatories on the
partnership's loan account at Central Trust. Robert and Monica
10 In the notice of deficiency as to 1980, respondent had
determined that eight specified checks drawn on the Cocoa Trusts
Escrow Fund, in amounts totaling $143,260, constituted unreported
1980 income from the Cocoa Trusts to petitioners. Respondent has
conceded four of these checks, totaling $43,260. Our findings
relate only to the remaining four checks totaling $100,000.
11 In the notice of deficiency, respondent determined that
eight checks, totaling $31,300, were 1981 income to Robert. By
stipulation, respondent conceded the eighth check, a $2,000 check
to Maximum Management, an entity described infra at L.
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