- 4 - proprietorship. Demetree and Associates’ principal business activities were the leasing and management of commercial warehouses owned by partnerships in which Arthur was a partner. The total management responsibilities relating to Demetree and Associates were minimal (e.g., the collection of rents and supervision of repairs). From 1983 through 1991, David occasionally assisted Arthur by performing services for Demetree and Associates. David also signed, pursuant to a power of attorney, Arthur’s name on Demetree and Associates’ business checks and deposit slips, including checks payable to himself or to third parties on his behalf. Arthur did not deduct the amounts he transferred to David, issue David Forms W-2, Wage and Tax Statements, or issue Forms 1099-MISC, Miscellaneous Income. Arthur and Naomi reported the income attributable to Demetree and Associates on the Schedules C, Profit or Loss From Business, accompanying their 1983, 1984, 1985, and 1986 joint Federal income tax returns. In 1986, Arthur and Naomi lent David funds to purchase a one-third interest in a partnership formed to build North Lane Plaza (NLP), a strip mall. The following year, Arthur and Naomi also lent David funds to start and operate Scooper’s Ice Cream (Scooper’s) in one of NLP’s stores. Scooper’s produced losses during all its years of operation until David sold it in 1989. In 1987, 1988, 1989, and 1992, David claimed net operating lossPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011