- 3 -
law practice was conducted apart from AGI.2 AGI’s principal
activity was providing legal support services to attorneys to
whom it leased space. AGI therefore engaged in three kinds of
activities. It provided legal support services, leased office
space, and offered consulting services.
AGI employed an office staff consisting of at least three
clerical support personnel to provide legal support services.
Services included client intake, answering phones, taking
messages, filing documents at the courthouse and State capitol,
process serving, express mailing, binding briefs, conducting
legal research, typing briefs and legal memoranda, taking
dictation, managing a file room, and photocopying. AGI also
maintained an updated law library and conference facilities for
its tenants. AGI provided other services including a security
service, trash removal, janitorial services, coffee service, and
general utilities. AGI owned the office equipment it leased to
the law firm and “nine or ten” other tenant attorneys. AGI was
reimbursed by the law firm, other attorneys, and petitioner
husband for their shares of payroll and office expenses. AGI
also offered petitioner husband’s consulting services to its
tenants. Tenant attorneys leased space in the office building
principally to obtain these services that AGI offered.
Petitioner wife exclusively managed AGI’s leasing activities
and legal support services during the years at issue. This
involved supervising AGI’s office staff, procuring supplies,
2The law practice leased space from AGI and used AGI’s
services.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011