- 28 - After his termination and the conclusion of the settlement negotiations, petitioner felt he had no viable career as a talent agent. He also did not believe he could start his own talent agency. Petitioner thus decided to pursue a career as a talent manager and as a film and television producer. Talent managers are not allowed to procure employment on behalf of clients and do not benefit from the fixed commission rates that talent agents are entitled to receive under their agreements with the talent guilds. Around May 1996, he started Hofflund Polone with Judy Hofflund (a former partner at UTA). During 2001 or 2002, petitioner formed a production company named Pariah Productions. As of the time of trial, petitioner had at least two television shows on the air--Family Affair and Hack. Several pilots he produced had not yet been picked up as series, and he had not produced any feature films. Payments Made to Petitioner Pursuant to the Settlement Agreements Pursuant to the employment termination agreement, UTA paid petitioner $950,000 in 1996 and $1,050,000 in 1998. Petitioner included these amounts on his respective Federal income tax returns for 1996 and 1998. Pursuant to the defamation agreement, UTA paid petitioner $1 million on or about: (1) May 1, 1996 (May 1996 payment), (2) November 11, 1996 (November 1996 payment), (3) May 5, 1997 (MayPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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