- 4 -
In 1983, the taxable year in issue, petitioner was actively
engaged in the practice of law, although he also served as a
consulting engineer and was involved in farming.2 Petitioner
maintained a law office in Riverside, California, and he
specialized in the formation of financial institutions, such as
banks, savings and loan associations, and thrift and loan
associations. Petitioner formed more than 23 financial
institutions in southern California.
Neither in 1983 nor at any other time relevant to this case
did petitioner have any expertise in accounting or tax matters,
nor did he ever attempt to render advice on those subjects.
In 1983, petitioner was financially well-off and
sophisticated. For that year, he earned a net profit of $122,464
from his law practice, and he derived capital gains from stock
transactions in the net amount of $115,5083 and interest in the
amount of $21,747. In addition, petitioner had equity interests
in: (1) An equipment rental proprietorship, (2) a partnership
known as Fontana Bancorp Development, (3) five jojoba
partnerships, see pp. 5-6, and (4) an S corporation known as
2 Any income that petitioner may have earned in 1983 from
consulting as an engineer or from farming was minimal.
3 In one instance, petitioner parlayed a $5,000 investment
in Corona Bancorp in June 1982 into a $98,508 sale in Dec. 1983.
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