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In addition to his employment with Bay Point, Inc.,
petitioner operated a construction consulting business as a sole
proprietorship. In the conduct of his own business, petitioner
utilized the services of various subcontractors. Petitioner
maintained records showing the individual payments made to these
subcontractors throughout the year. Petitioner compiled these
individual payments and timely provided each subcontractor with a
requisite Form 1099 reflecting the sum of the payments.
During the taxable years 1989, 1990, and 1991, petitioner
was also a shareholder of an S corporation known as Aquamar
Production Research Corp. (Aquamar). Petitioner’s interest in
Aquamar ranged from 13 to 14 percent. In 1990 and 1991,
petitioner was a general partner in a real estate partnership
known as Skyview Development. Petitioner had a 33.33-percent
profits and loss interest in Skyview Development. In addition,
petitioner and his wife also owned various rental properties
during the years in issue.
On or before April 15 of each of the taxable years in issue,
petitioner filed an Application for Automatic Extension of Time
to File U.S. Individual Income Tax Return (Form 4868).
Petitioner timely filed his 1989, 1990, and 1991 Federal income
tax returns on or about August 14, 1990, August 15, 1991, and
August 15, 1992, respectively.
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