- 4 - corporations’ employees and wrote checks for the corporations’ combined employment tax liabilities. In exchange for these services, petitioners’ corporations paid SWAS a handling fee. Petitioners’ Federal income tax returns have never included a Schedule C, Profit or Loss From Business, for a sole proprietorship known as SWAS or a partnership return on Form 1065, U.S. Partnership Return of Income, for a partnership known as SWAS. Mr. Kanz began working for petitioners and their corporations in 1981. At that time, Mr. Kanz had known petitioners for approximately 10 years. Mr. Kanz, then a licensed public accountant, performed services as an independent contractor for petitioners’ corporations. His responsibilities included preparation of payroll tax returns and financial statements, the reconciliation of bank statements, and management of petitioners’ corporations’ financial affairs. He performed these services for petitioners’ corporations and SWAS from 1981 to July 1990. He billed each corporation for professional fees based on his number of hours of service for that corporation. Initially, SWAS maintained a payroll checking account at Brooks Field National Bank in San Antonio, Texas. In March 1987, SWAS opened another account at Trinity National Bank in San Antonio, Texas. Petitioners and Mr. Kanz were the only personsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011