-8- of Consultants. Robert owned 75 percent of the stock of Consultants and Ney owned 25 percent.4 During 1977, 1978, and 1979, Robert worked full time at his various duties at Consultants, including soliciting new clients, servicing existing clients by evaluating their business performance, reviewing clients’ financial and tax records, and preparing draft tax returns. At the height of its business, Consultants had about 100 clients. C. SSI and Its Chartered Representatives In 1980, Robert founded and became president of Structured Shelters of Cincinnati, Inc., hereinafter sometimes referred to as SSC, which took over the functions of Consultants.5 Initially, SSC served as a prototype for Structured Shelters, 4 The parties have stipulated that Consultants “was comprised of” Robert, Monica, and Ney. However, Monica did not own any of Consultants’ stock, and she was not a compensated officer for Consultants’ fiscal years ending May 31 of 1979, 1980, and 1981. Consultants’ corporate tax return for its fiscal year ending May 31, 1979, declares that Consultants was not incorporated until June 1, 1979, even though it had business income and business expenses reportable by it for the fiscal year before it was incorporated. 5 So stipulated. However, stipulated exhibits show that SSC was incorporated in late June or early July 1981. One of those exhibits shows that SSC was operated as a partnership from June 1, 1981, to Aug. 1, 1981. The parties also have stipulated that “Structured Shelters of Cincinnati was formed in the late 1970’s by Robert and Monica Iles and others.” It may be that Structured Shelters of Cincinnati was a partnership which was somehow a predecessor of SSC, the corporation, even though the chronology does not seem to fit. As shown infra in table 1, Robert was a prolific creator of business entities. SSC figures more importantly infra items M. and N.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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