-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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
Last modified: May 25, 2011