-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.
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