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escrow account (which by then had grown to $181,280) as their own
asset. On the application, this was offset by a $176,000
[$176,500?] "contingent liability". There is no indication that
petitioners understood they had any obligation to return the
money to the FE Trust.
The $176,500 withdrawn from the FE Trust's Southern Ohio
Bank account on December 17, 1981, was 1981 income to
petitioners.
J. Random Processing Services
Random Processing Services' bank account was the principal
bank account for Random Processing Services, Inc., and served as
a depository account for the Random Report fees paid by SSI
clients.14 In 1980, five checks totaling $8,675 were drawn on
Random Processing Services' bank account to petitioners. All
$8,675 was 1980 income to petitioners. On March 17, 1981, a
$1,000 check was drawn on this account to Monica. This $1,000
was 1981 income to petitioners. In 1982, two checks totaling
$15,000 were drawn on this account to Monica. All $15,000 was
1982 income to petitioners.
K. Monica Iles Shelters Trustee Account
The Monica Iles Shelters Trustee account served as a
depository account for investors in various tax shelters promoted
14 This bank account is different from the SSI bank
account described supra, which was used primarily as a depository
for Chartered Representative Fees and SSI client funds; the two
accounts are in the same bank.
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