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information regarding any debt that might have generated
forgiveness of debt income as reported by the Robinsons.5
Mr. Robinson, an officer and the sole shareholder of Career,
and Mrs. Robinson performed services for Career, but they did not
report salary or wage income on their 1992 or 1993 return. Mr.
Robinson provided substantial services to the corporation in his
capacity as an officer. Because of his expertise as a certified
aircraft mechanic and pilot, he was involved in overseeing the
day-to-day operation of the aircraft brokerage segment of
Career’s business. He was personally involved in the inspection,
negotiation, and purchase of used aircraft and parts, and he
traveled extensively for this part of the business. Mr. Robinson
took part in the actual inspection of purchased aircraft and
parts. He worked a minimum of 60-70 hours a week for the
company.
Mrs. Robinson was involved in the day-to-day administrative
details of Career. Along with two others, Mrs. Robinson prepared
corporate checks and coded them for posting to the general
ledger. She was also responsible for marketing. Most
importantly, Mrs. Robinson was the primary dispatcher for the
freight and passenger charter activities, including the
coordination and readying of the planes and crew for the freight
and charter businesses. Although she was also the property
5 Petitioners, on brief, do not attempt to characterize the
$31,015 amounts reported for 1992 and 1993 as income from
forgiveness of debt. They agree that those amounts are income,
but disagree that it is income subject to self-employment tax.
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