-33-
note for $700,000 plus $105,000 interest--in the amount of
$17,500 a month starting 6 months after delivery. Robert, acting
on behalf of the Rise Trust, signed the security agreement in
connection with the $700,000 note. Robert individually
guaranteed the note. SSI paid the $25,000 deposit on February 5,
1982. Robert, acting on behalf of the Rise Trust, accepted
delivery of the Jet on February 16, 1982. The FE Trust paid the
$375,000 that was due at delivery.
Petitioners, as 76-percent owners of the Rise Trust, had
1982 income in an amount equal to 76 percent of the $400,000 of
1982 payments made by their controlled entities ($25,000 by SSI,
plus $375,000 by the FE Trust) for the Jet, or $304,000.
Q. Structured Shelters Securities
In August 1982, petitioners and Doyle formed Structured
Shelters Securities, Inc., hereinafter sometimes referred to as
SSSI. SSSI was incorporated in Delaware. SSSI was formed on the
advice of Finkelstein, Thompson, and Levenson in order to bring
SSI's investment offerings into compliance with Federal
securities laws and regulations. SSSI was to act as a registered
broker-dealer of securities; it was to locate investments for,
and to act as an investment adviser and financial planner to,
SSI's clients.
As we have found (supra C. SSI and Its Chartered
Representatives), in 1982 SSI paid $229,737.27 as capital
contributions to SSSI ($170,500 directly to SSSI and $59,237.27
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