David W. Hill - Page 4

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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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