-34- 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.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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