- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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