-50-
None of the foregoing amounts were reported on petitioners'
1980 tax return.
There is no indication of offsetting deductions or credits.
We conclude, and we have found, that respondent has shown by
clear and convincing evidence that petitioners had an
underpayment of tax for 1980.
(2) 1981
In the notices of deficiency for 1981, respondent determined
that petitioners had unreported income from (1) the Cocoa Trusts,
(2) the Monica Iles Shelters Trustee account, (3) Random
Processing Services, Inc., (4) the FE Trust, (5) SSI, and (6)
Maximum Management, and had unreported capital gain from the
attempted sale of SSC.
Pursuant to the parties' stipulation, we have found that in
1981, seven checks totaling $29,300 were written to Robert from
the Cocoa Trusts Escrow Fund. We have found that the entire
amount was 1981 income to petitioners. Supra G. Cocoa Trusts.
Pursuant to the parties' stipulation, we have found that in
1981, 29 checks totaling $42,961.11 were drawn on the Monica Iles
Shelters Trustee account to Robert or to third parties on
petitioners' behalf. We have found that the entire amount was
1981 income to petitioners. Supra K. Monica Iles Shelters
Trustee Account.
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