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to Finkelstein, Thompson, and Levenson), and these contributions
were allocated among Robert (52 percent), Monica (24 percent),
and Doyle (24 percent).
Petitioners listed $263,260.11 paid-in capital for SSSI as a
personal asset in the net worth statement that they submitted in
connection with a 1983 loan application. Supra O. Rolls Royce.
A July 31, 1983, SSSI balance sheet shows total paid-in capital
of $448,665.
The capital contributions by SSI to SSSI on behalf of
petitioners are 1982 income to petitioners.
R. Structured Shelters Financial Management
In August 1982, petitioners and Doyle formed Structured
Shelters Financial Management, Inc., hereinafter sometimes
referred to as SSFMI. SSFMI was incorporated in Delaware at the
same time as SSSI. SSFMI was formed on the advice of
Finkelstein, Thompson, and Levenson to act as an investment
adviser to SSI's clients.
As we have found (supra C. SSI and Its Chartered
Representatives), in 1982 SSI paid $14,000 as capital
contributions to SSFMI, and these contributions were allocated
among Robert (52 percent), Monica (24 percent), and Doyle (24
percent). Petitioners listed $43,103.69 paid-in capital for
SSFMI as a personal asset in the net worth statement that they
submitted in connection with a 1983 loan application. Supra O.
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