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reflect that Monica Ramsden, an employee of Taxman, was elected
secretary during the meeting that allegedly took place on October
5, 1987, and that she remained in that capacity until at least
October 7, 1991. Dianna Jilek, an employee of Taxman from 1988
until 1992, was designated an officer of Taxman and WFIC on the
companies’ annual reports. Ms. Jilek did not know she was
designated an officer until she saw her name on Taxman and WFIC’s
annual reports.
Taxman issued Forms W-2, Wage and Tax Statement, to
petitioner for each year in issue. Taxman paid petitioner
$12,000, $20,186, $18,208, and $25,008 in 1990, 1991, 1992, and
1993, respectively.
On September 30, 1994, Mr. Jondahl died. At the time of his
death, Mr. Jondahl owned 95 percent of Taxman’s stock. Mr.
Jondahl left his entire estate to Mrs. Jondahl. In November
1995, petitioner and Mrs. Jondahl sold Taxman to an unrelated
third party.
C. WFIC and Petitioner’s Real Estate Business
On October 12, 1978, petitioner received his real estate
agent’s license. In January 1985, petitioner began selling real
estate as an agent for WFIC. WFIC was organized in 1949 as a
real estate corporation by Lester Smith. Mr. Smith served on
WFIC’s board of directors and as its president from its
incorporation until 1990 or 1991. Mr. Smith died in 1993.
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