Peter Spuler, Jr. - Page 4

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               During the years in issue petitioner was employed full-time            
          as an engineer for Greenhorne & O’Mara, Inc.  Petitioner received           
          a bachelor of science degree in engineering and master’s degrees            
          in public policy and business.  In 1995 petitioner accepted the             
          position at Greenhorne & O’Mara, Inc., of Director of Marketing             
          for Federal Land Development and Infrastructure.                            
               In 1986 petitioner filed a certificate of incorporation for            
          Synergetics Engineering Corp. (SEC).  According to a business               
          plan dated March 1988, the mission of SEC was as follows:                   
                    Synergetics has as its core mission to seek unique                
               profitable business opportunities in the technical                     
               services market by focusing its total efforts on the                   
               high growth environmental quality segments of the                      
               overall market.  The venture will always be market-                    
               driven, with primary attention to client needs.  The                   
               management team will always nurture a direct personal                  
               relationship with each major client, within mutually                   
               shared objectives of unquestioned long-term technical                  
               reliability and uncompromised attention to long-term                   
               service needs.                                                         
               For the taxable year ending July 31, 1987, SEC filed a Form            
          1120S, U.S. Income Tax Return for an S Corporation.  The return             
          reflects that petitioner, his wife, and other family members                
          owned 100 percent of the shares of SEC.  The return also                    
          reflected total income of $6,991, expenses of $9,313, and an                
          ordinary loss of $2,322.                                                    
               For the years in issue, no Forms 1120S were filed on behalf            
          of SEC.  The record is unclear to what extent SEC conducted any             
          business during the years 1988 through 1994.  Apparently during             

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