John H. Hudgens III - Page 3

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          officer training course at Fort Knox, Kentucky.  In August 1990,            
          petitioner enrolled at Emory University School of Law (Emory) in            
          Atlanta, Georgia, to obtain an LL.M. in taxation.  Petitioner               
          graduated with an LL.M. from Emory in May 1991.                             
               Prior to his graduation from Emory, petitioner began                   
          discussions concerning the possibility of his employment with The           
          Southeastern Trust Co. (STC), a privately owned, State-chartered            
          trust company.  Because STC was a young company, it was initially           
          able to offer petitioner only a part-time position.  Petitioner             
          worked part-time for STC from September 1, 1991 to January 31,              
          1992.  In February 1992, petitioner became a full-time employee             
          of STC as one of STC's five principal trust officers.  Between              
          August 1, 1991 and January 31, 1992, petitioner also worked part            
          time for Jack Williamson & Associates (Williamson), a small                 
          accounting firm.  Petitioner anticipated that his part-time                 
          employment with Williamson would be temporary.  Petitioner also             
          attended additional National Guard annual training after his                
          graduation from Emory.  On his 1991 Federal income tax return,              
          petitioner reported income in the amount of $2,800 from 5 months'           
          employment at Williamson2 and $6,217 from STC.  Petitioner also             
          reported $7,123 of income from the National Guard activities.               



          2  For 1991, petitioner reported wages in the amount of $16,140.            
          According to the two Forms W-2 attached, petitioner received                
          wages in the amounts of $6,217 from STC and $7,123 from the                 
          Department of Defense.  We assume that the remaining $2,800 was             
          received from Williamson.                                                   

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