Eyefull Incorporated - Page 12

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               In this case the absence of documentation reflects not only            
          the flexibility and informality that the circumstances permitted,           
          but also a deliberate policy.  Mohney testified that he has been            
          indicted on obscenity charges over a hundred times.  Having                 
          learned from experience that documentary evidence of his                    
          relationship to the adult entertainment businesses he controlled            
          posed a risk of incrimination, he kept such documents to a                  
          minimum.                                                                    
               Contemporaneous documentation of a business relationship is            
          not altogether lacking.  On his individual income tax returns for           
          the years 1985-91 Mohney described his principal business as                
          consulting and reported the payments from petitioner and the                
          other corporations he managed as gross receipts from this                   
          business.  In addition, we have the uncontradicted testimony of             
          Hagerman and Krontz that they understood a consulting agreement             
          to exist, and the testimony of Mohney that he always expected               
          compensation for his work.  To be sure, such testimony serves               
          their interest, but we cannot reject it for that reason alone.              
          Lewis & Taylor, Inc. v. Commissioner, 447 F.2d 1074, 1077                   
          (9th Cir. 1971), revg. T.C. Memo. 1969-82; Loesch & Green Constr.           
          Co. v. Commissioner, 211 F.2d 210, 212 (6th Cir. 1954), revg. a             
          Memorandum Opinion of this Court.                                           
               The evidence strongly suggests that Mohney did expect to               
          receive payment in some form from petitioner.  In addition to the           
          payment in 1991, Mohney received a payment from petitioner in               




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