- 14 - U.S. Army. After being honorably discharged from the Army in 1953, petitioner entered the construction business. Petitioner eventually became the president and sole shareholder of R&H Paving, Inc., a paving contractor. Prior to making the commodity trades with Hunter, petitioner held various investments during the 1970's and early 1980's. Petitioner's basic requirement in an investment was a good cash- flow, in order to counter the cyclical nature of his construction business. Petitioner was not averse to risk in an investment since he was accustomed to a considerable amount of risk from the construction industry. Generally, petitioner relied on either Roy Tolson, an accountant and business adviser, or Joe Rasey, a business associate, to locate investments which satisfied his investment criteria. Before making an investment, petitioner would personally analyze the transaction. In June 1980, petitioner hired Donald Short (Short) to be his personal business adviser and controller for R&H Paving, Inc. Short was a certified public accountant (C.P.A.), licensed to practice in California. Prior to being hired by petitioner, Short was employed by Edward White & Co., the C.P.A. firm that prepared petitioners' tax returns. While Short worked at Edward White & Co., he prepared petitioners' tax returns. Short testified that he was well aware of petitioner's tax positionPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011