-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.Page: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 Next
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