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and SSI consented to Robert's transfer of SSC to Maerki. On that
same day, a certificate for 255 shares of SSC stock was issued to
Christina M. Gambetta (Maerki's sister), and a certificate for
245 shares of SSC stock was issued to John A. Gambetta (Maerki's
brother-in-law). Maerki was to pay Robert $150,000, in three
equal installments on May 1, August 1, and November 1, 1982.
On or about April 29, 1982, Maerki lent $55,000 to SSC, of
which (1) SSC paid $50,000 to SSI as the May 1, 1982, required
installment, and (2) SSC paid $1,923.29 to SSI as the required
interest, under the Maerki-Robert sales agreement. On September
1, 1982, SSC paid $10,000 to Robert. On Schedule D of their 1982
tax return, petitioners reported $61,923 as a long-term capital
gain from partnerships and fiduciaries, related to Robert's sale
of SSC.
Petitioners received $60,000 long-term capital gain income
and $1,923.29 interest income for 1982 on account of Robert's
sale of SSC.
O. Rolls Royce
On February 12, 1982, Robert, as trustee for the Riago
Trust, bought a Rolls Royce car for $79,000. SSI paid the
$10,000 deposit on the car on February 10, 1982, and the $69,000
balance on the car on February 16, 1982. SSI also paid the
$4,345 Ohio sales tax on the car on March 12, 1982. SSI's
general ledger listed the $79,000 in wire transfers and the
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