- 5 - indefinite period of time. Mr. Bell anticipated that it would take a minimum of 18 to 24 months to structure accounting and administrative departments and have them running smoothly enough that petitioner’s full-time presence and participation would no longer be required. During 1994, 1995, and 1996, petitioner worked for Bellmark in Los Angeles 287, 281, and 282 days, respectively. He was paid $97,200 for his Los Angeles work during 1994; however, he did not receive the agreed upon compensation for 1995 or 1996. Moreover, petitioner was not reimbursed by Bellmark for any expenses incurred in the years at issue. Nevertheless, petitioner continued to devote the majority of his time to Bellmark in the hopes of eventually receiving such moneys.3 On their joint Federal income tax return for 1994, petitioners included a Schedule C, Profit or Loss From Business (Schedule C), in connection with petitioner’s financial and tax consultant business. That Schedule C included the following income and expenses: 3 The principal reason why petitioner was not compensated and reimbursed was that some of the recordings of Bellmark contained the musical talents of several artists, and each of those artists was entitled to royalties, an element which was apparently not anticipated by Mr. Bell or petitioner and that apparently heavily drained Bellmark’s resources.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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