- 19 - earned a six-figure salary. Petitioners’ income (exclusive of partnership losses) of $146,879 and $187,674 in 1982 and 1984, respectively, shows that petitioners stood to benefit substantially by the deductions and credits that Whitman offered. Clothier explained to petitioner the immediate tax benefits of the investment. The expectation of such benefits motivated petitioner to invest in Whitman. At trial, petitioner made a transparent attempt to downplay his role in the success of Apex, describing his duties as “strictly limited to production”. He described his business aptitude by saying: “I think everybody has strengths and weaknesses in what they do, and mine is, I’m more mechanically inclined.” As to the source of Apex’s success, petitioner said: “I’ve been lucky”. Petitioner also testified that he has been diagnosed with dyslexia and that he does not enjoy reading. Petitioner’s claim that he lacks sophistication is self- serving and inconsistent with the facts. It is readily apparent that petitioner completely dominates the operations of Apex and is responsible for its remarkable success. His alleged choice to devote his efforts to the production operations of Apex as well as his aversion to reading are not inconsistent with his possessing business acumen. We note that petitioner acquired equipment in the name of Lake Stevens Leasing, which he described as a d/b/a for himself, that leased equipment to Apex.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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