Cristeen B. Comey - Page 25




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          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 or           





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