- 2 - registered as an investment adviser with the Securities and Exchange Commission. In the mid-1970s, Southeast Trust’s name was changed to Trust Investment Management (Trust Investment). As owner and operator of Trust Investment, petitioner managed a $2 million investment portfolio, including employee benefit accounts. From 1983 through 1993, petitioner, while continuing to operate Trust Investment, worked as senior vice president for First Tennessee Investment Management (First Tennessee). From 1989 through 1993, petitioner deposited a portion of the management fees he earned from Trust Investment into certificates of deposit, municipal bonds, and a cash management fund. In 1993, First Tennessee terminated petitioner’s employment for violating bank and corporate policies. In that year, an FBI special agent interviewed petitioner relating to petitioner’s alleged misappropriation of First Tennessee funds (i.e., five checks totaling approximately $28,000 and made payable to Trust Investment). Petitioner timely filed his 1989 through 1993 Federal income tax returns. On the Schedule C, Profit or Loss From Business, accompanying petitioner’s 1993 return, he deducted, from gross receipts and sales, $65,586 of returns and allowances. By letter dated June 2, 1994, the Internal Revenue Service notifiedPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011