Robert E. Iles and Monica M. Iles - Page 58

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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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