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Blazyk’s only contact with Universal occurred when petitioner
asked WWMC to issue the checks for his services to Universal.
Until June 2000, Mr. Blazyk did not know and never had any
contact with Mr. Chisum.
The parties have stipulated that Universal is not legally
entitled to hold a real estate license or conduct a mortgage
business.
According to California Department of Real Estate records,
WWMC was petitioner’s employing broker in 1993 and was still
petitioner’s employing broker in 1997.
Facts Relating to Petitioner’s Motions and Respondent’s Motion
for a Penalty Under Section 6673
On October 7, 1999, the Court filed respondent’s Motion to
Consolidate for Trial, Briefing, and Opinion. A copy of this
motion was mailed to petitioner on October 1, 1999. The motion
stated:
the position of counsel for respondent * * * is that
the Universal Trust is a sham and that individual items
of income are taxed to the individuals Kevin R.
Johnston and Julia Ghavami personally, and individual
expense items, if substantiated, are deductible by them
personally.
On November 8, 1999, the Court filed a copy of respondent’s
Requests for Admission, which had been served on petitioner on
November 5, 1999. These requests sought information relating to
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