-8- BTG Corp. BTG Corp. (BTG) was incorporated in Delaware on September 28, 1981. Prior to July 30, 1985, BTG was a dormant corporation. BTG had been formed by AMCOR, a California corporation, which incorporated and sold other corporations primarily to attorneys for tax planning activities. From 1984 to 1988, AMCOR had only two employees, Robert Burton (Burton) and Lisa Aspoy. Ms. Aspoy is, and at all relevant times was, the wife of Mark Schiavenza (Schiavenza). Schiavenza is an attorney specializing in the field of taxation. From October of 1975 to January or February of 1981, he practiced law with Harry Margolis, whose tax planning strategy (which involved the circular transfer of funds through the use of offshore entities, trusts, and shell corporations) has been repudiated by this Court on numerous occasions. See Marine v. Commissioner, 92 T.C. 958 (1989), affd. without published opinion 921 F.2d 280 (9th Cir.1991); Erhard v. Commissioner, T.C. Memo. 1991-290, modified T.C. Memo. 1992-376 and T.C. Memo. 1993-25, affd. 46 F.3d 1470 (9th Cir. 1995); Leonard v. Commissioner, T.C. Memo. 1985-51, affd. without published opinion sub nom. Robinson v. Commissioner, 816 F.2d 684 (9th Cir. 1987). Schiavenza represented various real estate developers and referred them to AMCOR as clients. Schiavenza also represented Escondido Property Investment Corp. (EPIC), Oi Weng Co. Ltd., aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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