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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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