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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.
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Last modified: May 25, 2011