-18- payments. Ms. Jackson used that approach as an inducement for petitioner to advance more funds into their joint venture by providing him with ownership as security and rental income in exchange for additional funding. We note that the machinery was worth about $100,000, the equivalent of about one-sixth of the funds advanced. The substance of petitioner’s involvement with Ms. Jackson and her corporation was to profit from obtaining government road contracts. Respondent’s position that petitioner was a passive investor who advanced two-thirds of a million dollars with only limited security and no stock ownership does not ring true. Respondent, concerning whether petitioner should be treated as a creditor, refers to petitioner as a "white knight" who advanced funds to Ms. Jackson and Cities. It is difficult to imagine any reason for petitioner’s substantial participation other than his interest in the "pot" of profits at the end of Ms. Jackson‘s promotional "rainbow" and the rent he was to receive from leasing the machinery. Early in the relationship, petitioner was to receive 50 percent of the profits from the government road contract. When Cities' involvement in the government contract was canceled and things began to deteriorate, petitioner was promised all of the receipts from the government contracts--which, at that time,Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011