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the entire amount was 1982 income to petitioners. Supra J.
Random Processing Services.
Pursuant to the parties' stipulation, we have found that 36
checks totaling $198,850 were drawn on SSI's Southern Ohio Bank
account to petitioners or on their behalf. We have found that
the entire amount was 1982 income to petitioners. Supra C. SSI
and Its Chartered Representatives.
Pursuant to the parties' stipulations, we have found that in
1982 SSI paid $170,500 to SSSI as capital contributions to SSSI,
and that SSI paid $59,237.27 to Finkelstein, Thompson, and
Levenson as capital contributions to SSSI.
The parties did not stipulate the status of check no. 3205,
written to Howard Blumenthal in the amount of $18,716, dated
September 30, 1982. However, the parties stipulated a
memorandum, also dated September 30, 1982, by Monica to Basti.
In this letter, Monica directs Basti to treat this check and two
other checks as follows:
These funds should be posted as contributed capital to
the broker/dealer. [SSSI] * * * The capital
contribution on behalf of Adrian Doyle, Robert Iles,
Sr., and Monica Iles is 24%, 52% and 24% respectively.
Neither side has drawn our attention to anything in the record
contradicting the clear import of this evidence, and we have not
found any such contradicting evidence. We conclude, and we have
found, that respondent has shown by clear and convincing evidence
that SSI paid $18,716 to Howard Blumenthal as a 1982 capital
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