- 3 - For several years petitioner was employed as manager of the Wall Street office of Loeb Rhodes & Co., a securities brokerage firm. Subsequently, he was affiliated with Tyz-All Plastics, Inc., as an employee, officer, director, and shareholder. His affiliation with this corporation ended in 1986. Prior to and during the years at issue, petitioner traded securities for his own account. The parties have stipulated that he did not engage in these securities transactions as a dealer.2 During the years at issue petitioner held an interest in several partnerships and S corporations. In 1986 he and two other individuals incorporated KRS Restaurant Corp. (KRS) for the purpose of operating a restaurant. Later that year petitioner and his two associates formed the Carlisle Inn Joint Venture (CIJV) and Harrisburg Inn Joint Venture (HIJV) to operate two motels. Acquisition of the motel and restaurant businesses was financed in part by loans that petitioner and his associates guaranteed. The Forms 1065 filed by CIJV and HIJV reflect that a 50-percent interest in each joint venture was owned by an S corporation called KBS Motel Corp. (KBS). The Forms 1120S filed 2The record contains additional facts concerning petitioner's background and trading activity that may be relevant to the reasonableness of petitioner's reliance on his accountant's substantive tax advice for purposes of sec. 6653(a) and to the existence of reasonable cause for a waiver under sec. 6661. In view of our disposition of both of these issues, however, further details would be superfluous, and we have therefore omitted them.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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