Luis Acle, Jr. - Page 6

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          of the loss was allowable.  Respondent has not sought to disallow           
          the remaining $2,379 of the loss, and we therefore do not address           
          respondent’s calculation of the allowable amount of the loss.               
          2.  Petitioner’s Business Activities                                        
               During the year in issue, petitioner was engaged in certain            
          business consulting activities.  In connection with these                   
          consulting activities, petitioner served as the chief executive             
          officer of an entity named North American Free Trade Association            
          (NAFTA), which is incorporated in Mexico.  In this position,                
          petitioner would provide services to foreign companies seeking to           
          do business in Mexico.  Petitioner would allow his clients, the             
          foreign companies, to use the address of NAFTA’s office in Mexico           
          City.  NAFTA maintained a bank account in Mexico.                           
               Petitioner also operated a business activity under the name            
          of Occidental Utilities (OU).  While petitioner entered into at             
          least one agreement with a client in which petitioner asserted              
          that OU was a Delaware corporation, petitioner does not recall              
          incorporating OU, and in any event petitioner conducted business            
          only as a sole proprietor under that name.  In this business                
          activity, petitioner provided consulting services within the                
          utilities industry.  In 1996 or 1997, petitioner entered into a             
          contract with a business known as San Luis Tank to provide                  
          consulting services.  In connection with this agreement, San Luis           
          Tank issued petitioner a Form 1099-MISC, Miscellaneous Income,              






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