Robert M. Temple - Page 18




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               In 1990, petitioner received checks totaling $74,360 for the           
          services he provided as a veterinarian and from the sale of                 
          animals.  Petitioner deposited checks totaling $74,360 into the             
          Bank One 855 account, which Mrs. Temple had signatory authority             
          over.                                                                       
               In 1991, petitioner received checks totaling $16,059 for the           
          services he provided as a veterinarian and from the sale of                 
          animals.30  Petitioner deposited checks totaling $16,059 into the           
          Bank One 855 account, which Mrs. Temple had signatory authority             
          over.                                                                       
               In 1992, petitioner received checks totaling $17,880 for the           
          services he provided as a veterinarian and from the sale of                 
          animals.  Petitioner deposited checks totaling $7,670 in the Bank           
          One 855 account and checks totaling $1,410 in the Bank One 863              
          account.  Mrs. Temple had signatory authority over both accounts.           
               Amounts deposited into the Bank One 855 account in the name            
          of Plume Enterprises and the Bank One 863 account in the name of            
          Galingale Group constituted income of petitioner.  Petitioner               
          earned the income, he and his wife exercised total dominion and             
          control over those funds, and they expended the funds for their             
          personal expenses.  From these two accounts alone, Mrs. Temple              



               30One check for $600 was actually made payable to one of               
          petitioner’s customers, Wendy Arbogast, but deposited into the              
          Bank One 855 account.  See appendix I.                                      





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