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by the Blackbird Investments trading account, and from a Toronado
Resources account. These funds were used by Ms. Ford to purchase
the Montecito home and for Mr. Ford’s payment of taxes owed from
the 1970s. In March 1986, Mr. Ford authorized a withdrawal from
a Solar Aquafarms, Ltd. account, which Ms. Ford used to buy fur
coats at the Pappas Fur Co. in Canada. Mr. Ford also transferred
money from various Canadian corporate accounts, derived from
International Tillex stock transactions, into his own bank
accounts. Further, in April 1986, funds were transferred from at
least one of the Canadian corporate accounts into a bank account
in Beverly Hills, California, belonging to Ms. Ford. Ms. Ford
purchased a house in Montecito, California, in 1986, financed by
a mortgage for which funds from a Blackbird Investments account
were pledged as security. Approximately $25,000 was also taken
from a Toronado Resources account for a downpayment. At the time
of the purchase, Blackbird Investments had a brokerage account in
Canada which traded in International Tillex stock. On June 12,
1986, an additional $250,000 was wired into Ms. Ford’s bank
account in California for the purpose of making home improvements
and buying home furnishings. These facts show that each
petitioner had control, and made frequent beneficial use, of the
income in the Canadian accounts based on which respondent
determined the deficiency and additions to tax stated in his
notice of deficiency. The Court concludes that respondent has
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