- 5 - owned by Lewis Simmons (Simmons), who rented the residence to petitioner. Petitioner incorporated JJH in 1985 purportedly to conduct his tax return preparation business. At all relevant times, JJH’s address and business location were at the Muehl residence. The Muehl residence has three levels: A basement, a main floor, and an upstairs floor where the bedrooms are located. Petitioner conducted his return preparation business in the basement, and he saw clients at his office in the basement. Tim has been collecting Walt Disney toys and characters since he was very young, and his collection today includes numerous figurines and other collectible items of a variety of sizes and types (Disney collection). Petitioner is similarly intrigued with Mickey Mouse, Donald Duck, and the Walt Disney fantasy, and he enjoys sharing his affinity for these characters with others.2 When Tim left home for college, he left behind his Disney collection, and petitioner displays the Disney collection throughout the basement where he meets tax and accounting clients. During all relevant periods, petitioner was the beneficial owner of all JJH’s stock. Petitioner did not have an employment contract with JJH, and he was not an employee of JJH. JJH had no 2For example, petitioner submitted his brief to the Court on a diskette bearing Mickey Mouse’s image.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011