-59-
ratios of 52, 24, and 24, respectively) in which to own the Jet.
We have found, pursuant to the parties' stipulations that in
February 1982, SSI paid the $25,000 deposit on the Jet and FE
Trust paid the $375,000 delivery installment on the Jet. A
dispute then developed between the Jet's seller and the Rise
Trust trio. It is not clear what eventually happened to the Jet.
However, in March 1983, on a net worth statement petitioners
submitted in connection with a loan application, petitioners
claimed that their 76-percent interest in the Jet was worth
$361,000. Also, on a net worth statement dated October 23, 1984,
the Riago Trust claimed that its 76-percent interest in the Jet
was worth $361,000. We have found that 76 percent of SSI's
($25,000) and FE Trust's ($375,000) 1982 payment--$304,000--is
1982 income to petitioners. Supra P. Saberliner Jet Aircraft.
We have found that, during 1982, Maximum Management wrote
$6,049.81 in checks to Watkins to pay for Watkins' services in
taking care of petitioners' children. For reasons set forth
supra note 20, we conclude that three other checks, totaling
$352.97 do not constitute 1982 income to petitioners. For
reasons set forth in our analysis of petitioners' 1981 income
from Maximum Management, supra, we conclude that Maximum
Management had a 1982 net profit of $6,049.81, which results in
$6,049.81 additional 1982 income to petitioners.
We so hold.
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