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telephone calls to these people or groups. No agreements were
entered into between any of the parties. Petitioner also
attended trade shows and conferences related to mass transit
during the years at issue. Petitioner maintained a journal of
these meetings and events. Petitioner also noted in his journal
different cities that were considering a transportation system.
When meeting with members of the group, petitioner referred to
them in his journal as staff.
There is evidence of one agreement with another individual.
Exhibit 14-R is an agreement, typed on Sky Shuttle, Inc.
stationery, between Allen Beishline and Sky Shuttle, Inc./Charles
Willits in which Mr. Beishline grants to Sky Shuttle, Inc., and
petitioner the rights to Mr. Beishline’s wheel-hub motor design
for use in transit vehicles. The agreement was dated June 25,
1979, and was to expire in 10 years. It appears from the
Virginia proposal and petitioner’s journal that Sky Shuttle was
still using the wheel-hub motor design. Petitioner testified
that if the wheel-hub motor design was used, Mr. Beishline would
receive a fee.
On Schedule C filed with the 1992 joint return, petitioner
reported $500 in gross income5 and claimed $12,347 in expenses
for a net loss of $11,847. On Schedule C filed with the 1993
5 It is not clear from the record the nature of this income
or whether it was even related to the Sky Shuttle activity.
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