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believe, and have found, that Mr. Del Bosque used those funds to
open a brokerage account in January 1987. We conclude that, in
determining the deficiencies in tax, Mr. Del Bosque’s 1986 net
worth should include $12,000 in the First Bank East account.
c. Mrs. Jacobsen’s Chase Manhattan Money Market
With Checks Account
Mrs. Jacobsen had a Chase Manhattan “money market with
checks” account (the MMWC account). On December 31, 1986, there
was a balance of $8,618 in that account. The account balance was
not included as an asset in the Jacobsens’ 1986 net worth
statement. Respondent concedes that $8,618 should be included on
that net worth statement.
d. The Jacobsens’ Joint Chase Manhattan Bank
Money Market Account
The Jacobsens had a joint money market account at Chase
Manhattan Bank. This account was included as an asset valued at
$37,200 on the Jacobsens’ 1986 net worth statement. The $37,200
Agent Fisher used as the account balance was based on the amount
($37,200) reflected on financial statements the Jacobsens
completed in 1986; Agent Fisher did not confirm the account
balance as of December 31, 1986, with Chase Manhattan Bank. Mr.
Jacobsen contends that the account balance was at least $38,200
on December 31, 1986. The statement of the account dated
February 11, 1987, reports that the account balance was $38,324
as of January 13, 1987. The February statement shows that the
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