- 25 - The parties have stipulated that during 1992, $3,400 in dividends was paid on stock registered in Landtrak’s name. The notice to Mr. Comey for 1992 included in Mr. Comey’s income $2,919 of the $3,400 in dividends paid on stock registered in Landtrak’s name. Respondent is aware of the discrepancy between the $2,919 in dividends determined in the notice and the $3,400 in dividends described in the stipulation, but has decided not to seek an increased deficiency. In light of the parties’ stipulation and respondent’s decision, we find that $2,919 of dividends was paid in 1992 on stock registered in Landtrak’s name. Mr. Comey’s only argument is that these dividends are Landtrak’s income, because Landtrak owned the stock registered in its name. Sales Proceeds Received by Landtrak in 1992 In August 1992, shares of stock in 15 companies, which had been registered in Mr. Comey’s name, but were recently reregistered in Landtrak’s name, were transferred to an account maintained with PaineWebber and held in Landtrak’s name. On August 19, 1992, the stock in the PaineWebber account was sold for aggregate proceeds of $591,438. On August 21, 1992, a PaineWebber check for the proceeds was deposited in a checking account maintained in Landtrak’s name with the M&I Bank of Menomonee Falls, Wisconsin. On August 26 orPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011