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FINDINGS OF FACT1
Petitioner resided in Chicago, Illinois, when he petitioned
the Court. His business is insurance sales, and he has been in
this business since 1969. Petitioner and his wife, Lucia A.
Whitmer, filed a 1987 Form 1040, U.S. Individual Income Tax
Return, using the status of “Married filing joint return”.
Although respondent’s notice of deficiency for the 1987 taxable
year was issued to both petitioner and Lucia A. Whitmer,
Mrs. Whitmer did not petition the Court with respect thereto,
and, accordingly, she is not a party here.
Petitioner formed a wholly owned corporation, Whitmer
Agency, Inc. (Whitco), on or about September 16, 1974, to issue
life and health insurance policies and annuities. Petitioner was
Whitco’s president, and, in that capacity, he entered into a
“General Agent’s Contract” (Agent’s Contract) with ITT Life
Insurance Corp. (ITT) on October 22, 1981. Petitioner personally
guaranteed Whitco’s performance under the Agent’s Contract.
Petitioner, in his capacity as Whitco’s president, also entered
into an “Advance Commission and Loan Agreement for General Agent”
(Agreement) with ITT on November 19, 1981. Petitioner personally
guaranteed Whitco’s performance under the Agreement. The Agent’s
Contract and the Agreement authorized Whitco to solicit and
1 Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the attached exhibits
are incorporated herein.
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