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fraud and other additions to tax for 1984, 1985, and 1987; and
(2) whether petitioner is entitled for 1986 to deduct $6,033 in
interest expenses and for 1987 $108,037 in legal expenses. All
issues relating to Barbara B. Rehtorik have been settled.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
In 1983, petitioner, as sole shareholder, incorporated
Government Securities Corp. (GSC) as a Florida corporation.2
Until May 1987, petitioner was president of GSC.
In 1984, petitioner incorporated Government Securities Group
of America (GSC America) as a Florida corporation and as the
parent holding company of GSC. Petitioner was sole shareholder
and president of GSC America.
GSC was engaged as a broker/dealer in the purchase and sale
for and to investors of Government-backed securities, such as
Government National Mortgage Association and Federal National
Mortgage Association mortgage-backed securities, and U.S.
Government zero coupon bonds.
Separately from GSC’s above brokerage activities on behalf
of investors, GSC solicited funds from a limited number of
individual investors to be invested on behalf of GSC by
petitioner and by Oscar F. Gomez (Gomez), vice president and
2 GSC was originally incorporated under the name of the
Federal Government Securities Corp. (FGSC). In 1984, FGSC
changed its name to GSC to comply with Federal law.
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