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Revenue Service in District Counsel's offices in Virginia and
Indiana. In 1978, he opened a private law practice in Dale,
Indiana. Since 1978 and during all relevant years, petitioner's
practice was conducted as a partnership known as Price & Bradley,
in which petitioner held a 51-percent interest.
In the early years of petitioner's practice, Walter Scott
Taylor, Sr., Walter Scott Taylor, Jr., and Brenda Fant Taylor
were petitioner's primary clients. The Taylors were successful
Indiana coal mine owners, and petitioner handled all of their
legal affairs.
In 1979, the Taylors acquired an interest in Speedmart, Inc.
(Speedmart), an Indiana corporation. Speedmart operated a
convenience store located in Cannelton, Indiana. The Cannelton
store had lost money every year since it opened. The Taylors
owned a majority of Speedmart's outstanding shares. Petitioner
owned 20 percent of Speedmart's shares, which he acquired as
compensation for legal services rendered.
In 1982 or 1983, the Taylors moved their residence and coal
mining activities to Alabama, and petitioner took over the day-
to-day management of Speedmart. Petitioner served as president
and a director of Speedmart. In addition, he was the manager of
the Cannelton store. Speedmart was authorized to pay petitioner
an annual salary of $18,000, but Speedmart never made any salary
payments to petitioner.
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Last modified: May 25, 2011