- 29 - Accordingly, we also conclude that Landtrak did not become the direct or indirect owner of Mr. Comey’s portfolio in 1987 or 1988, whether or not Mr. Comey sold Lumatron stock to Landtrak as he claims. To the contrary, we conclude that Mr. Comey remained the title owner as well as the owner for tax purposes of his portfolio, until Mr. Comey had the stock in his portfolio reregistered in Landtrak’s name in mid-1992. Moreover, for the reasons also set forth below, we hold that although Landtrak became the title owner of Mr. Comey’s portfolio in mid-1992, it did not become the tax owner. Landtrak (and Landtrak’s purported ownership of Mr. Comey’s portfolio) are disregarded for tax purposes, because Landtrak did not have a business purpose or engage in business activity after Mr. Riopelle’s ownership ended in 1988. In addition, there is no evidence that Landtrak had any beneficial interest in, or dominion or control over, the stock registered in its name. Purported Transfer of Mr. Comey’s Portfolio to Lumatron in 1978 and Landtrak in 1987 or 1988 Mr. Comey contends that he transferred his stock portfolio to Lumatron in 1978. He further contends that ownership of that portfolio effectively passed to Landtrak in 1987 or 1988, when he assertedly sold his Lumatron stock to Landtrak. Mr. Comey specifically contends that his 1978 transfer to Lumatron was made pursuant to an “Inventor’s Agreement” betweenPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011