-37-
On their 1982 tax return, petitioners reported (1) $121,918
gross income and $106,416 net profit from Robert's role as trust
manager (presumably from Riago Trust), (2) $7,899 gross income
and $154 net profit from Maximum Management, (3) $178,658 as
grantor trust loss from Riago Trust, (4) $61,923 long-term
capital gain from the sale of SSC, and (5) a $3,589 short-term
capital gain pass-through from Riago Trust. Supra N. Second Sale
of Interest in Structured Shelters of Cincinnati. Petitioners
reported their total tax liability as $3,029, all from self-
employment tax.
4. Structured Shelters' and Riago Trust's 1981
and 1982 Tax Returns
On its tax return for its fiscal year ended July 31, 1981,
filed on April 6, 1982, SSI reported gross income of only $8,347
and undistributed taxable income as a loss of $353,185.56. This
tax return was signed by Monica. Petitioners did not report any
pass-through income or loss from SSI on their tax return for
1981. SSI did not file a tax return for its fiscal year ending
July 31, 1982.
Fiduciary tax returns for the Riago Trust for 1981 and 1982
were filed on September 10, 1988, several months after
petitioners filed their 1981 and 1982 tax returns. The Riago
Trust's tax returns for these years treated the Riago Trust as a
grantor trust, with Robert as the grantor. Petitioners' 1981 and
1982 tax returns include flow-through income and losses from the
Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 NextLast modified: May 25, 2011