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In the notice of deficiency for 1980, respondent determined
that petitioners had unreported income from (1) the Cocoa Trusts,
(2) the Monica Iles Shelters Trustee account, and (3) Random
Processing Services, Inc.
In 1980, Monica wrote four checks totaling $100,000 to
Robert from the Cocoa Trusts Escrow Fund. As our Findings of
Fact show (supra H. Robert Iles, et al.), $90,000 of this total
went to pay off a loan by a partnership in which Robert had a 65-
percent interest. Monica testified, without contradictory
testimony by Robert, that the primary motive was to remove the
lender's security interest in assets in petitioners' personal
residence and business office. Another check to Robert, for
$6,000, was a commission payment. We have found that all
$100,000 was 1980 income to Robert.
Pursuant to the parties' stipulation, we have found that in
1980, 38 checks totaling $45,631.78 drawn on the Monica Iles
Shelters Trustee account were written to petitioners or on their
behalf. We have found that the entire amount was income to
petitioners. Supra K. Monica Iles Shelters Trustee Account.
Pursuant to the parties' stipulation, we have found that in
1980 five checks totaling $8,675 drawn on Random Processing
Services' bank account were written to petitioners. We have
found that the entire amount was income to petitioners. Supra J.
Random Processing Services.
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