- 4 -
Builders, Inc. (Gibraltar). During 1987, petitioner received wages
from Gibraltar totaling $123,671; for the first 5 months of 1988,
petitioner received wages from Gibraltar totaling $66,382.
On June 21, 1988, petitioner and Robert Randall, the president
and apparently the sole or at least the majority shareholder1 of
Robert Randall Co., entered into an agreement (called and
hereinafter referred to as the Sunbelt Project Working Agreement),
pursuant to which petitioner agreed to be the regional manager
responsible for locating, acquiring, and developing properties in
the Sacramento area for multifamily housing on behalf of
partnerships or other entities to be controlled by Robert Randall
or his affiliate. In accordance with the provisions of the Sunbelt
Project Working Agreement, beginning in June 1988, and throughout
all years under consideration, Robert Randall Co. made monthly
payments, labeled "advances", to finance petitioner's living
expenses. In addition to these advances2, Robert Randall Co. paid
wages to petitioner. FICA (Social Security tax) was withheld on
these wages, but Federal income taxes were not.
The amount of wages and advances paid to petitioner were as
follows:
1 The record is not clear on this point. Robert Randall
testified that he was "the chief executive officer, the
president, the chairman, and the owner" of Robert Randall Co.
2 The use of the word "advances" is not meant to give a
legal characterization of the monthly payments.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011