- 4 -
a publicly traded Utah corporation of which petitioner was
president.
When investors requested an accounting of funds transferred
to petitioner, petitioner did not provide such an accounting, and
petitioner did not otherwise disclose to investors the status of
the funds.
Because petitioner used the funds received from investors to
invest on his own behalf, specific, identifiable proceeds
realized on transactions petitioner entered into with the funds
constitute proceeds and specific items of capital gain or loss
realized by petitioner personally, adjusted for petitioner's tax
bases in the various transactions where his tax bases are
established in the record.
Also, petitioner realized additional items of specific,
identifiable income in the form of partnership distributions,
royalties, interest income, fees, and various checks that were
not deposited into petitioner’s bank accounts but that were
either made payable to petitioner or endorsed over to petitioner.
The following schedule summarizes, separately for each year
in issue and by category of income only, the total of the
specific items of income that petitioner realized, that were
determined by respondent, and that we sustain:1
1 The total income figures reflected in the schedule take into
account any tax basis in the various specific stock and commodity
investments that petitioner has established.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011