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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 interest
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