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he did have some formal control and much practical control over
most of petitioner’s income.
Although the matter is not free from doubt, we conclude that
it is more likely than not that Popovic had enough control to be
an insider with respect to petitioner during each of the years in
issue; we have so found.
(3) Vecchio
Vecchio was petitioner’s bingo operator from 1976 through
1978, well before the years in issue. As president and one-fifth
owner of P&R, Vecchio was involved in petitioner during the years
in issue only to the extent of having an interest in the
sublessor of the Center, where petitioner’s bingo games were
being conducted during 1984 and part of 1985. The rent that
petitioner paid to P&R ($26,000 per year) was less than 10
percent of petitioner’s reported direct bingo expenses. Supra
table 1.
On opening brief respondent states several times that
Vecchio was an insider, but the only explanation given is that he
“is a former president and bingo operator.” We have found that
Vecchio had earlier operated petitioner’s bingo games, but do not
find in the record evidence that he had been petitioner’s
president at any time. On answering brief, respondent does not
even mention Vecchio.
On the basis of the record in the instant case, it appears
that, during the years in issue, Vecchio did not have any formal
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