- 9 - compensation was paid by Norcom to Quest before April 1992. However, minimal expenses Quest incurred in 1991 were reimbursed by Norcom. b. April 1992 Through 1996 The relationship between Quest and Norcom changed significantly in April 1992 when Mr. Lombardi resigned from Norcom. Immediately after Mr. Lombardi’s resignation, Mr. McColl assumed oversight of the day-to-day operations of Norcom, especially with respect to oversight of Norcom’s finances.6 Mr. McColl moved his office to Norcom and worked at Norcom on a full- time basis. In addition to oversight of Norcom’s operations, Mr. McColl became a Norcom officer.7 From June 1992 until December 1993, he served as Norcom’s secretary and treasurer. From August 1992 until December 1993, he also served as the executive vice president of Norcom. The record does not indicate that Mr. McColl was ever compensated by Norcom. 6 Mr. Arnold at least nominally assumed some of Mr. Lombardi’s responsibilities by temporarily taking the positions of president and CEO of Norcom. Despite holding these offices, the evidence does not indicate that Mr. Arnold was actively involved in the management of Norcom. 7 Petitioner claimed that Mr. McColl was not an employee of Norcom. Because respondent has not disputed this claim, we have accepted it as a stipulated fact. Accordingly, we have not considered whether Mr. McColl was an employee of Norcom for Federal tax purposes and that any work he performed for Norcom was under such employment and not on behalf of Quest. Sec. 3121(d)(1) (defining an employee of a corporation to include its officers).Page: 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