Nicholas M. Romer - Page 4




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          petitioner associated himself with Great Lakes Air d/b/a Cirrus             
          Air Charter (Great Lakes) and Cirrus Flight Operations (Cirrus).            
          Great Lakes possessed a charter certificate and operated an air             
          charter business.  Cirrus sold fuel and provided maintenance to             
          small aircraft.  During the years in issue, Great Lakes and                 
          Cirrus were owned, in part, by Richard Cross (Cross), who was a             
          pilot for Sun Country Airlines, and in part by an unrelated                 
          business entity known as General Housewares.                                
               Pursuant to an agreement with Cross, petitioner flew his               
          aircraft on charter flights under Great Lakes’ charter                      
          certificate.  Sometimes, Cirrus would arrange for other pilots to           
          fly petitioner’s aircraft on charter trips.5                                
               Apparently, petitioner was entitled to receive all the                 
          income generated from flights using his aircraft and was credited           
          with all the income and charged with associated expenses incurred           
          by Great Lakes or Cirrus in an account that he maintained with              
          Great Lakes (Great Lakes account).  Romer & Co. provided                    
          accounting services for Great Lakes and Cirrus and prepared their           
          Federal income tax returns.                                                 






               5 The record is unclear as to the exact relationship of                
          these other pilots to Cirrus and to petitioner.  One of the                 
          pilots, Richard Matthews, testified that his income from the                
          flights in question was reported on Forms 1099 issued by Great              
          Lakes and stated:  “I believe we’d be called subcontractors”.               




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