Steven J. and Terry L. Namyst - Page 4

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               In March 1996, Mr. Kerkinni approached petitioner and                  
          informed him that IMC could no longer afford to pay him a salary.           
          Petitioner claims that at that time, he agreed to continue                  
          working for IMC without a salary.  Petitioner and Mr. Kerkinni              
          agreed that IMC would reimburse petitioner for any expenses he              
          paid in performing his duties as an employee.  The reimbursement            
          payments were to be made whenever and in whatever amounts IMC               
          could afford to make them.  Mr. Kerkinni also agreed that IMC               
          would purchase any of petitioner’s old tools that were being used           
          by employees of IMC.  At Mr. Kerkinni’s request, petitioner kept            
          an inventory list of the tools and equipment owned by him and               
          used by IMC employees and added to the list annually.                       
               During 1996, 1997, 1998, and 1999, petitioner paid expenses            
          related to his work at IMC.  Petitioner’s expenses included                 
          travel and purchases of new equipment.  IMC issued checks to                
          petitioner between March and December 1996, and in 1997, 1998,              
          and 1999.  The amounts of these checks were not reported to                 
          petitioner on a Form W-2, and petitioners did not report the                
          amounts of the checks on their 1996, 1997, 1998, or 1999 Federal            
          income tax returns.  The checks from IMC were issued almost every           
          month, although on different days each month.  The amounts of the           
          checks varied, from $500 (January 2, 1997) to $4,000 (September             
          20, 1996), and were generally in round numbers.  Petitioner did             
          not receive a statement allocating the amounts of the checks                






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