-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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