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Hugh Z. Graham, Jr. (Mr. Graham), an executive vice-
president of the Columbia, South Carolina, office of STC
described the business of STC as
65 to 80 -- 65 to 70 percent investment management for our
clients.
The rest of the services that we provide are the other
fiduciary kinds of things that you would see in a trust
company such as bill paying, and report making, and you
know, investment, objective-setting, and those kinds of
things, like that.
And then, of course, there is the necessity to -- for
all the peripheral things, like the fiduciary tax aspects of
what we do * * *
Mr. Graham further testified that (1) petitioner's duties
included account administration and primarily new business
development; (2) all of the principal trust officers performed
similar duties; (3) excluding petitioner, none of the principal
trust officers were certified public accountants or possessed a
master's degree in taxation, and only one other was an attorney;
(4) petitioner prepared most of the fiduciary tax returns for the
Columbia office; (5) petitioner served as treasurer of STC; and
(6) all of the principal trust officers provided some tax advice.
Petitioner's description of the duties he performed at STC
generally matched Mr. Graham's; however, petitioner emphasized
the tax aspects to a greater extent.
On his 1990 and 1991 Federal income tax returns petitioner
claimed employee business expense deductions for the cost of
obtaining his LL.M. degree in the amounts of $11,476 and $13,033,
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