- 3 - Mr. Welker, who had a high school education, prepared petitioners' tax returns for each of the years in issue.1 Mr. Welker worked at Miller-Senate Finance Co. (Miller- Senate) as the office manager/loan officer. As such, he ran the day-to-day operations of Miller-Senate. His duties included: (1) Approval of vehicle loans; (2) preparation of documents relating to such loans; (3) arrangement of credit lines; and (4) collection and repossession activities. Virtually all of the loans Mr. Welker approved on behalf of Miller-Senate were loans for cars purchased from Bob Brockland Pontiac-GMC (Brockland Pontiac). Brockland Pontiac utilized Miller-Senate for the financing of new and used cars sold to high risk customers.2 Miller-Senate obtained these high risk loans (the high risk loans) by purchasing chattel mortgage contracts from Brockland Pontiac. Miller-Senate lost approximately $300,000 on these loans. Mr. Welker and Brockland Pontiac had an arrangement whereby Brockland Pontiac made payments to Mr. Welker in the amount of $100 in cash for each high risk loan Mr. Welker purchased on 1 Unless otherwise indicated, all descriptions refer to the 1984, 1985, 1986, and 1987 tax years. 2 High risk customers were those who could not qualify for conventional financing through banks and dealer financing.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011