Robert E. Iles and Monica M. Iles - Page 28

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          or managed by SSI.  In 1980, 38 checks totaling $45,631.78, drawn           
          on the Monica Iles Shelters Trustee account, were written to                
          petitioners or to third parties on petitioners' behalf.15  All              
          $45,631.78 was 1980 income to petitioners.  In 1981, 29 checks              
          totaling $42,961.11, were drawn on the Monica Iles Shelters                 
          Trustee account to petitioners or to third parties on                       
          petitioners' behalf.16  All $42,961.11 was 1981 income to                   
          petitioners.                                                                
          L.  Maximum Management                                                      
               Petitioners formed Maximum Management, as Monica's sole                
          proprietorship, to pay payroll and other expenses of SSI and                
          other entities petitioners controlled.  Maximum Management                  
          received the funds to pay these expenses through intercompany               
          billings to various entities controlled by petitioners.  During             
          1981, Maximum Management wrote 1 $300 check to Monica17 and 44              
          checks totaling $5,225.9218 to Jacqueline B. Watkins, hereinafter           

               15   One of these checks, number 214, is in the amount of              
          $1,500.  The check stub shows $609.11 of this amount as "Cash".             
          Respondent included only this $609.11 in the notice of deficiency           
          determination.                                                              
               16   One of these checks, number 245, is in the amount of              
          $450.  In the ledger for this account, $154 of this amount is               
          distributed to "Iles draw".  Respondent included only this $154             
          in the notice of deficiency determination.                                  
               17   Respondent's proposed finding of fact asks that we find           
          that the check to Monica was for $500.  However, the only source            
          that respondent cites for this proposition shows that the entire            
          check was for $300.                                                         
               18   Respondent's proposed finding of fact departs in                  
                                                             (continued...)           



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