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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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