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to petitioners’ children.6 Also during 1999, Wright & Associates
issued checks totaling $5,510 to Consultation & Mediation.
During 2000, Wright & Associates transferred to petitioners
amounts totaling $32,075 either by check or transfer to
petitioners’ personal bank account. Of the total amount
transferred to petitioners, $29,405 constituted personal
distributions. Wright & Associates also issued checks to
petitioners’ children totaling $14,715, and to Consultation &
Mediation totaling $1,250.
During 2001, Wright & Associates distributed to Mr. Wright
$87,864.64. In addition, for each of the years in issue, Wright
& Associates paid for petitioners’ health insurance. The
premiums for this insurance for 1999, 2000, and 2001, were
$5,287, $6,625, and $9,208, respectively, for which petitioners
claimed a 60-percent deduction.
D. Offshore Banking, Investments, and Transactions
During the years in issue, petitioners maintained an
offshore bank account and credit card. The offshore bank account
was at Leadenhall Trust Company, Ltd. (Leadenhall), in the
Bahamas. Leadenhall issued petitioners a Mastercard credit
card.7 In addition, Mr. Wright made offshore investments for
6Petitioners’ children paid back $916 to Wright &
Associates.
7The Mastercard credit card issue by Leadenhall operated
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Last modified: May 25, 2011