- 2 -
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1991, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
After settlement, the primary issue for decision is whether
petitioners are entitled to deductions for claimed losses
relating to a closely held corporation. All references to
petitioner are to Daniel F. Nix.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Austin, Texas.
In 1986, petitioner was employed in the telecommunications
industry as a sales director. While in this position, petitioner
identified what he regarded as a new market for single line
telephones to complement more expensive business telephone
systems that his employer sold.
On April 17, 1987, after investigation and consultation with
others, petitioners, David Morales (Morales), and John Amos
(Amos) formed Telim Communications Corp. (Telim) as a California
corporation to manufacture and sell single line telephones. The
board of directors of Telim consisted of Morales, Amos, and
Mrs. Nix.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011