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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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