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time the petition was filed, petitioner was a resident of Alaska,
and INI was a dissolved Alaska corporation that had conducted
operations and had its principal place of business in Alaska.2
Petitioner timely filed, pursuant to extension, his 1984
Federal income tax return on June 21, 1985. Petitioner timely
filed his 1986 Federal income tax return on April 15, 1987.
INI's Federal income tax return for the fiscal year ended
September 30, 1984 (TYE 9/84), was timely filed on December 15,
1984.
Petitioner received a B.A. degree in economics from Brigham
Young University and, in 1959, a J.D. degree from New York
University. Petitioner took two elementary accounting courses as
an undergraduate. In law school, petitioner studied corporation
law and took one elementary tax course. Petitioner is admitted
to practice law in New York, Utah, and Alaska. While serving as
an assistant U.S. attorney for the District of Alaska from 1968
until 1975, petitioner tried some tax cases. During the years in
issue, petitioner was a sole practitioner whose practice included
appellate litigation and criminal, corporate, and personal injury
law.
2 INI was originally incorporated under Alaska law on
Apr. 6, 1983, as PBS of Alaska, Inc. On Aug. 15, 1983, its name
was changed to INI Builders, Inc. On Oct. 14, 1991, INI was
involuntarily dissolved by the Alaska commissioner of
corporations.
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