-28- 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...)Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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