- 5 -
* * * The problem was where was I going to put it? I
knew I couldn’t put it in my own hands. I didn’t want
to put it back into a mutual fund which was costing me
money every year for fees and everything else. I
decided I would buy this house and rent it to this
Section 8 woman.
* * * I withdrew * * * $49,997.15 * * * so it went from
Fidelity Insurance to the corporate account of Marlene
Hope, Inc.
* * * * * * *
I never touched any of that money. It never went
through my fingers at all.
1. Marlene Hope, Inc.
Marlene Hope, Inc. (MHI) was created in the 1970s and
subsequently incorporated in the State of Rhode Island as a for-
profit corporation.4 Petitioner’s daughter, Marlene Hope
Kirshenbaum5 (petitioner’s daughter), is the president and sole
shareholder of MHI.
MHI is engaged in the business of real estate purchasing,
selling and development, residential real estate management, and
real estate mortgaging. MHI maintains its corporate funds in an
account with First Bank & Trust Co. MHI filed a Form 1120-A,
U.S. Corporation Short-Form Income Tax Return, for the taxable
year 1997 reporting total income of $9,679, total deductions of
4 We note that MHI’s business address and telephone number
is the same as petitioner’s residential address and telephone
number.
5 On his 1998 Form 1040, petitioner claimed a dependency
exemption for Marlene Hope Kirshenbaum, who was born in 1961 and
resides with him.
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