17 any relevant period. Pertinax's rent expense was not charged separately to its three corporate partners, but was absorbed in the 10 to 11 percent markup added to the costs that Pertinax invoiced to the partners. Mr. Munro reported $128,160 in rental income from the El Centro property on his 1987 U.S. Individual Income Tax Return. Mr. Munro's Working Conditions and Responsibilities In 1986 and 1987, Mr. Munro had a house in San Marino, California, about 5 miles from the El Centro property. However, he generally lived at another house in Santa Barbara, California, about 75 miles from the El Centro property. If Mr. Munro was not in the office on a particular business day, a designated executive of Pertinax called him at the end of the day to report on the day's business activities and to obtain operating instructions for the following day or days. Mr. Munro would give specific directions about what should be done regarding current sales, cash management, sales with interesting indications about the current market, and sometimes employee matters. A typical conversation would last between 10 and 30 minutes. In 1986 and 1987, Mr. Brewer coordinated sales activities, carried out Mr. Munro's policy directives governing marketing practices, gross profit margins, how competitive to get with a particular contractor, and so on, and conducted the daily telephone conversations with Mr. Munro. Mr. Munro made the final policy decisions for Pertinax and the other entities, includingPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011