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Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioners resided in Washington, D.C.
During the 1999 taxable year, petitioner Clifford L. Brody
was the chairman of the board, chief executive officer, and
shareholder of Kids Own America, Inc. (KOA). As of April 1999,
he owned 134,625 shares of common stock, or 53.37 percent, of
KOA. Petitioner Brody received from KOA for the 1999 taxable
year a Form W-2, Wage and Tax Statement, which reported “Wages,
tips, other compensation” of $266,083.34.
Also during the 1999 taxable year, petitioner Barbara J.
DeClerk was the treasurer, secretary, and director of KOA.2 In
addition to her positions at KOA, petitioner DeClerk was also a
fundraiser for IONA Senior Services. As a fundraiser, she
incurred expenses for clients’ lunches, telephone, and automobile
use. She received a Form W-2 from IONA Senior Services for the
1999 taxable year.
2 John Selvaggio, along with petitioners, was a Director of
KOA. We note that a Confidential Private Placement Memorandum
dated Apr. 1999, for KOA did not list petitioner DeClerk as a
director.
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Last modified: May 25, 2011