Robert E. Iles and Monica M. Iles - Page 34

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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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