- 4 - 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,Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011