-32-
$4,345 in sales tax that SSI paid on the Rolls Royce as
performance bonuses to Robert.
On February 16, 1983, title to the Rolls Royce was
transferred as a gift from Robert, as trustee for the Riago
Trust, to Robert individually.
Petitioners listed the Rolls Royce, valued at $90,000, as a
personal asset in the net worth statement that they submitted in
connection with a 1983 loan application. After the $30,000 loan
was approved, the bank took a security interest in the Rolls
Royce.
The $83,345 that SSI paid in 1982 to buy the Rolls Royce
($10,000 plus $69,000 plus $4,345) was 1982 income to
petitioners.
P. Saberliner Jet Aircraft
On February 5, 1982, Robert, acting individually and on
behalf of the Rise Trust, entered into an agreement to buy a
Saberliner Jet Aircraft, hereinafter sometimes referred to as the
Jet,22 for $1,205,000. This total was to be paid as follows:
$25,000 as a deposit that day, $375,000 at delivery, and a 1-year
22 There was not any declaration of trust or other formal
document establishing the Rise Trust. There were not any Rise
Trust bank accounts. The record does not indicate any "activity"
of Rise Trust other than being the named purchaser of the Jet.
As far as we can tell from the fragments of information in the
record, the Rise Trust is merely a name used by petitioners and
Doyle as a "straw man" in connection with their intended
coownership of the Jet, with Robert having a 52-percent interest,
Monica having a 24-percent interest, and Doyle having a 24-
percent interest.
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