-57-
contribution to SSSI. We have found that in 1982 SSI paid
$14,000 to SSFMI as capital contributions to SSFMI.
All the foregoing contributions were on behalf of Robert,
Monica, and Doyle. Robert held 52-percent interests in all three
corporations (SSI, SSSI, and SSFMI), and Monica and Doyle each
held 24-percent interests in all three corporations. Respondent
concedes on brief, and we agree, that petitioners' income does
not include the 24 percent allocable to Doyle. Thus, petitioners
had 1982 income in the amount of 76 percent (52 plus 24) of
$262,453.27 ($170,500 plus $59,237.27 plus $18,716 plus $14,000),
or $199,464.49, on account of SSI's 1982 payments of capital
contributions to SSSI and SSFMI on petitioners' behalf. We have
so found.
Respondent also asks us to conclude that--
An additional nineteen SSI checks, totalling $2,408.00,
represent payments for state registration fees or
accounting services for SSSI or SSFMI, and are also
contributions to the capital of SSSI or SSFMI. (RPFF
�� 255, 263, 264) All of these amounts were payments
by SSI to fund the personal acquisition by Robert Iles,
Monica Iles, and Adrian Doyle of individual ownership
interests in SSSI or SSFMI.
The cited proposed findings of fact direct our attention to one
$550 SSI check to Kolbinski and Kling, and two statements by
Kolbinski and Kling to SSSI for services rendered, in the amounts
of $300 and $750. Respondent does not direct our attention to
anything in the record, including respondent's tables and
explanations, that would show that in 1982 SSI paid any debt of
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