- 4 -
business consulting, tax advice, and return preparation. During
these years, petitioner traveled to Los Angeles from Memphis once
or twice a year.
During 1993, petitioner decided to resume his activity at
Nashville. Petitioner began renting a condominium there in late
1993. Also during 1993, one of his Los Angeles clients, Isabell
Records, Inc. d/b/a Bellmark Records (Bellmark), began
experiencing financial success with one of its recordings and,
thus, had an increasing need for petitioner’s services.
Due to the prospect of Bellmark’s increasing revenues, the
owner of Bellmark, Alexander Bell (Mr. Bell), requested during
the latter part of 1993 that petitioner devote his full time to
Bellmark matters and that petitioner remain in Los Angeles to be
"on call" for Mr. Bell and Bellmark. Mr. Bell believed that
Bellmark was on the verge of generating significant revenues
(which had not previously been the case), and he wanted
petitioner to work full time in setting up an accounting
department, structuring business administration policies, and so
forth. After discussing the matter with his wife, petitioner
Betty D. Harris, petitioner agreed to work for Bellmark full time
and live in Los Angeles provided that he would be compensated
$100,000 per year for his services, plus expenses. No time
limitation was placed on this arrangement; rather, the
arrangement between petitioner and Bellmark was to last for an
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011