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Hickman3 and petitioner Janice C. Hickman, who divorced sometime
after the years at issue, lived in Oklahoma City and Edmond,
Oklahoma, respectively. Petitioners timely filed a joint Federal
income tax return (return) for each of the years 1991, 1992, and
1993.
During the years at issue, petitioner, an orthodontist, was
the sole shareholder of F.E. Hickman, DDS Orthodontics, Inc.
(Hickman corporation). During those years, petitioner, who also
owned substantial interests in banks in and around the Oklahoma
City area, was (1) the director and the chairman of the board of
directors of Midwest National Bank (Midwest Bank), (2) a director
of The National Bank of Harrah (National Bank of Harrah), Harrah
National Bancshares, Inc. (Harrah Bancshares), and Midwest
National Bancshares, Inc. (Midwest Bancshares), and (3) the
director and chairman of the board of directors of Nichols Hills
Bank and Trust. As such, petitioner was aware of the financial
and business circumstances of those organizations.
The Hickman corporation maintained the F.E. Hickman, DDS,
Orthodontics, Inc., Retirement Plan and the Hickman corporation
profit-sharing plan until they were terminated on December 31,
1991, and January 31, 1992, respectively.
3 Hereinafter, references to petitioner in the singular are to
petitioner French E. Hickman.
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