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so found, and, by this reference, are incorporated herein.
Additionally, the "controlling cases", reported as Leema
Enterprises, Inc. v. Commissioner, supra, are incorporated by
this reference.
Petitioners Tom I. Lincir and Diane C. Lincir were married
and resided in San Pedro, California, when their petition was
filed. They were divorced in 1993. Petitioners are high school
graduates. Mr. Lincir has taken some junior college classes and
is trained as a metalworker. After graduating from high school,
Mrs. Lincir took some junior college courses in bookkeeping.
Between 1975 and 1982, petitioners operated two successful
physical-fitness businesses. One, Sta-Slim Products, engaged in
manufacturing light exercise items, and the other, Ivanko Barbell
Co., engaged in the importation and sale of weightlifting
equipment. Mr. Lincir was involved in every aspect of the
businesses, while Mrs. Lincir handled the accounts payable and
ran the office side of the businesses. By 1982, sales of the two
companies totaled more than $4 million annually.
Between 1976 and 1980, Mr. Lincir was also involved in
dealing in coins and precious metals. He attended weekly
seminars that had been formed to discuss investing in precious
metals.
Mr. Lincir additionally invested in real estate. One of his
associates in an apartment house venture introduced Mr. Lincir to
an accountant named Robert Schenkman, a specialist in real
estate. Mr. Schenkman became petitioners' accountant. He
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