-58- SSSI or SSFMI, and we have not found anything in the record that would so show. We conclude, and we have found, that petitioners' 1982 income on account of SSI's payments that constitute capital contributions to SSSI and SSFMI is $199,464.49. We have found that in February 1982, Robert, as trustee for the Riago Trust, bought a Rolls Royce car for $79,000; that SSI paid the $79,000 purchase price; and that a month later SSI paid the $4,345 sales tax. We have found that the entire $83,345 was recorded on SSI's books as performance bonuses to Robert and is 1982 income to petitioners. Supra O. Rolls Royce. We have found, based largely on SSI's books and records, that SSI's undistributed taxable income for its fiscal year ended July 31, 1982, is $1,413,319.10. This is after giving effect to deductions under section 1373(c) on account of more than $850,000 of SSI payments to or for the benefit of petitioners and Doyle during that fiscal year. We have found that petitioners' share of SSI's undistributed taxable income is $1,074,122.52; under section 1373(b), this is taxable to petitioners for 1982. Supra C. SSI and Its Chartered Representatives. We have found that on February 5, 1982, Robert bought the Jet, acting individually and on behalf of the Rise Trust. It appears that the Rise Trust was merely a name used by Robert, Monica, and Doyle (in their by-then usual ownership interestPage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
Last modified: May 25, 2011