Superior Proside, Inc. - Page 3




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               Murdock has at all times also served as petitioner’s                   
          president.  During 1995, 1996, and 1997, Murdock performed the              
          following services for petitioner:  (1) Solicited business on               
          behalf of petitioner; (2) ordered petitioner’s supplies;                    
          (3) entered into verbal and/or written agreements on behalf of              
          petitioner; (4) oversaw the finances of petitioner; (5) collected           
          moneys owed petitioner; (6) managed petitioner; (7) obtained                
          clients for petitioner; (8) hired and fired independent                     
          contractors on behalf of petitioner; (9) maintained customer                
          satisfaction; and (10) supervised all work done on behalf of                
          petitioner.  No other person performed any services on behalf of            
          petitioner.                                                                 
               During 1995, 1996, and 1997, petitioner did not make regular           
          payments to Murdock for his services.  Rather, Murdock obtained             
          funds from petitioner as his needs arose.  There were no set                
          intervals at which Murdock would take these moneys from                     
          petitioner.  Petitioner neither classified any payment as a                 
          dividend nor distributed any dividends to shareholders from 1995            
          through 1997.                                                               
          Petitioner’s Tax Reporting                                                  
               Petitioner timely filed Forms 1120S, U.S. Income Tax Return            
          for an S Corporation, and related schedules, for the 1987 through           
          1994 taxable years.  On these returns, petitioner did not report            








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