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residence. The Cheshires borrowed $99,000 to purchase the
property.
David Cheshire’s Retirement and Compensation Package
Mr. Cheshire took early retirement from Southwestern Bell
Telephone Co. (Southwestern Bell), effective January 1, 1992. As
a result, Mr. Cheshire received the following distributions (the
retirement distributions) in 1992:
Amount
Nations Bank of Texas, Trustee, for
“SBNCNPP EMP LUMP SUM” $199,771
Southwestern Bell LESOP for salaried employees 5,919
Southwestern Bell savings plan for salaried
employees 23,263
Southwestern Bell ESOP 971
Total 229,924
Of the $229,924, $42,183 was rolled over into a qualified account.
On January 31, 1992, Mr. Cheshire deposited $184,377 of the
retirement distributions into an account (account No. 9633-09) in
the name of “David D. Cheshire and Kathy Cheshire” at the Austin
Telco Federal Credit Union (the Austin Telco account).1 In 1992,
the funds in this account earned $1,168 in interest.
Petitioner was aware of Mr. Cheshire’s receipt of the
retirement distributions and the amount thereof, as well as the
interest earned on the Austin Telco account.
1 An additional $29,786 was deposited into this account
between Jan. 29 and Feb. 4, 1992. The record does not reveal the
source of these funds.
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