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Christopher’s Investment in the Russian Airplane Deal
The funds transferred on or about January 22, 1992, to
Nordbanken by James for the benefit of Quotum can be traced, in
part, to $500,000 contributed by James after he cashed
certificates of deposit held by the James P. Shea Living Trust.
The source of the additional $150,000 transferred to Nordbanken
does not appear in the record. On a date which also does not
appear in the record, Christopher gave James a check dated
January 30, 1992, for $150,000.9 Christopher gave the money to
James because James “had an opportunity to do some overseas
business that could possibly be profitable” and Christopher
wanted to invest in it. Christopher did not know much about the
venture or how his investment was to be used, but he understood
that, if the venture was successful and he was needed, he could
get involved in the day-to-day operations. The record does not
show what James did with Christopher’s $150,000.
Petitioners’ 1992 Returns and the Notices of Deficiency
Petitioners James and Patricia Shea filed a joint Federal
income tax return for 1992. On a Schedule C to that return,
James reported no gross income and a net operating loss of
9 Christopher’s check was dated 8 days after James
transferred the initial $650,000 to Quotum’s account at
Nordbanken.
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