Robert E. Iles and Monica M. Iles - Page 45

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               Respondent's determinations in the notices of deficiency are           
          based primarily on respondent's contention that petitioners had             
          unreported income from money petitioners appropriated for their             
          personal benefit from accounts that petitioners purported to                
          manage as trustees or fiduciaries for others.  We proceed to                
          consider the elements of this contention.                                   
               Table 1, drawn largely from a stipulated exhibit that Robert           
          prepared, shows many of the business entities Robert was                    
          associated with between 1973 and 1983.  Robert also was the sole            
          shareholder of Audio Research Analysts, Inc., and Super Swirl,              
          Inc., during part of the period before the Court.                           

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