- 3 - Petitioner’s officers and shareholders are two brothers, James M. Gibbs (James) and John W. Gibbs (John). James and John each own 50 percent of petitioner’s stock. James is petitioner’s vice president and secretary, and John is petitioner’s president and treasurer. James is primarily responsible for administrative, financial and tax matters, and his duties include running the office and dealing with the accountants. In contrast, John is primarily responsible for sales and promotion. James and John each attended college for 2 years. Other than James and John, petitioner employs approximately 8 to 10 individuals. None of these individuals exercises any managerial responsibility; rather, these individuals perform only clerical and sales-related duties. Both James and John spend much of their time traveling on business. John in particular spends between 30 to 50 percent of his time traveling, both domestically and internationally. Although James travels less frequently than John, some of his destinations are also outside of the United States. B. Steven Jaffe and the Firm of Coleman, Joseph & Jaffe Neither James nor John, nor any of petitioner’s other employees, possessed any expertise in either accounting or Federal tax matters. Accordingly, from 1991 through 1998, petitioner retained the accounting and consulting firm of Coleman, Joseph & Jaffe (CJ&J) to provide both accounting and taxPage: 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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