- 4 - Mohney served as an officer of several corporations in the Mohney Group. Many others, including petitioner, retained him as a “consultant”. Pursuant to a general understanding with Newlands, in his capacity as a “consultant” Mohney actually exercised the highest executive authority with respect to each of the corporations. Although he was ultimately accountable to the trustee, he understood that he had Newlands complete confidence and managed the companies effectively without supervision. Mohney submitted no written report of his work to Newlands but informed him of the progress of the companies under his control from time to time. On his individual income tax returns, Forms 1040, Schedule C, for each of the years 1985 through 1991, Mohney reported his principal business or profession as consulting and included payments he received from corporations in the Mohney Group in his gross receipts for the taxable year. The amounts reported as consultation income from the Mohney Group for each year are as follows: Year Number of Companies Total 1985 2 1$10,894 1986 2 36,823 1987 3 268,389 1988 4 175,917 1989 2 100,863 1990 12 364,448 1991 49 2,706,827 1This figure comes from a schedule prepared by petitioner. Mohney’s return shows a total of $30,408, which may include receipts from sources outside the Mohney Group.Page: 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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