- 12 -
1991 1992 1993 1994
David Deitsch $875,000 $2,350,000 -0- $1,000,000
Mordecai -0- -0- -0- -0-
Deitsch
Joseph Deitsch 875,000 2,350,000 -0- 1,000,000
Rachel Sandman 875,000 2,350,000 -0- 1,000,000
B. Mayer Zeiler -0- -0- -0- -0-
Jacob Pinson 875,000 2,350,000 -0- 1,000,000
Through withholding, income taxes were paid by the
recipients to the State of Israel on the amounts shown
above. Letters issued by Israeli authorities
certifying receipt of the income taxes specify that the
sums were due in respect of “commission fees” from FIL.
Additionally, as noted above, the parties stipulated,
without any reservations, the respective amounts of “Israeli
Income Tax Paid” by the movants. These stipulations, which we
now incorporate as explicit findings of fact, read:
Petitioner David Deitsch made the following income
tax payments to the State of Israel during the taxable
years 1991, 1992 and 1994:
Year Flocktex Payment Israeli Income Tax Paid
1991 $875,000 $296,554
1992 1,100,000 322,273
1992 1,250,000 382,177
1994 1,000,000 291,695
Petitioner Joseph Deitsch made the following
income tax payments to the State of Israel during the
taxable years 1991, 1992 and 1994:
Year Flocktex Payment Israeli Income Tax Paid
1991 $875,000 $296,554
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