Joseph J. House - Page 5




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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