- 16 - $78,199 on their joint income tax returns for 1988, 1989, and 1990, respectively. Also during 1988 through 1990, Mr. Speer and Mr. Paxson owned 51 percent and 49 percent, respectively, of the stock of Maximo Marina, Inc. (Maximo). Maximo was an S corporation that operated a full-service marina. Maximo also operated a used car sales operation (Maximo Motors) during part of 1988 and 1989. Mr. Speer would visit Maxima Motors on his way to HSN to check on its operations and review the prior day’s sales. Mr. Speer reported losses from Maximo of $477,836, $1,098,156, and $632,643 on petitioners’ joint income tax returns for 1988, 1989, and 1990, respectively. Mr. Speer did not keep a diary of the amount of time he devoted to Gateway and Maximo during 1988, 1989, and 1990. During those years, Mr. Speer performed work for approximately 30 family-owned companies; however, he devoted a majority of his time, approximately 75 percent, to his duties at HSN. Mr. Speer typically worked for these companies in an executive capacity, making management decisions. Generally, Mr. Speer would try to visit his various companies two or three times a week. OPINION Constructive Dividend Issue The first issue is whether petitioners received constructivePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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