Jack J. Grynberg - Page 4




                                         - 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