- 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 position
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011