- 4 -
apply simultaneously for the same parcel to increase their
chances of winning it.
Because Mrs. Grynberg was not versed in matters of oil and
gas leasing——she was a psychiatric social worker by profession——
petitioner invariably handled the business of JGA with the help
of employees. Acting on behalf of JGA, petitioner selected the
leases on which to file applications; the employees then prepared
and filed them under petitioner’s or his wife’s name. If peti-
tioner deemed a lease particularly valuable, he would instruct
the staff to file two applications for it, one in each name.
Under the Federal lottery system, both petitioner and Mrs.
Grynberg won leases, all of which were similarly managed by JGA.
JGA maintained one operating bank account, on which the
Grynbergs were signatories. Any income and expenses attributable
to the leases were deposited into and paid out of that account.
The sale proceeds of any leases were also transferred to the
operating account. Except for 1981 and 1982, the Grynbergs have
filed joint Federal income tax returns since 1959, reporting the
income and expenses of JGA on Schedules C, Profit or Loss From
Business.
During the quarters at issue, petitioner transferred mineral
leases and overriding royalties (collectively, mineral interests)
to his wife in an attempt to place the property beyond the reach
of a plaintiff class suing petitioner. See Danzig v. Jack
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011