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exchange. IBC’s corporate office was located at 5101 IDS Tower,
which was also petitioner’s office address.
Petitioner was a shareholder, director, and the chief
executive officer of IBC from April 1981 to August 1996; he was
its president from 1982 to 1995. Petitioner spent at least 80
percent of his time operating IBC. Petitioner received wages
from IBC and/or its subsidiaries for each of the years 1987 to
1995.4 Petitioner’s personal financial statements report the
following number of IBC shares owned by petitioner and their
value:
Date Number of shares Value
11/30/86 6,605,000 $1,321,000
08/31/88 472,200 4,958,100
10/31/89 472,200 5,961,525
10/31/90 472,200 2,361,000
09/30/91 472,200 472,200
01/31/92 472,200 118,050
03/31/93 472,200 47,250
02/28/94 472,200 47,200
In the mid-1980s, IBC decided to go into the entertainment
business, and, in 1984, it bought the CBS television affiliate,
KTAB TV, in Abilene, Texas. IBC paid $9 million for KTAB TV,
which was financed with a loan from Marine Midland Bank of New
York. The bank required petitioner to guarantee this loan.
Petitioner was to receive 1 percent or $90,000 as a guaranty fee
4Petitioner received wages of $471,805, $488,496, $419,712,
$495,226, $460,385, $539,149, and $8,351, in 1987, 1988, 1989,
1990, 1991, 1992, and 1993, respectively.
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