- 26 - entities. At the time Taxman was incorporated, petitioner was being sued as an individual and as sole proprietor of his tax preparation business. Petitioner’s goal of obtaining limited liability for his tax preparation business by operating his business through Taxman is a sufficient business purpose for Taxman to be recognized as a separate entity. See Moline Props., Inc. v. Commissioner, supra at 438-439. In addition, Taxman had employees, filed tax returns, maintained books, records, and a bank account, and held assets and liabilities. This level of ongoing business activity is also sufficient for the Court to conclude that Taxman was not a sham corporation. See id. WFIC was organized by Mr. Smith in 1949, and from 1988 until 1994, it operated a commercial real estate business. Until 1991, Mr. Smith remained actively involved in WFIC’s day-to-day business operations and had an office in Taxman’s business space. WFIC maintained books, records, and bank accounts and filed corporate tax returns. Petitioner applied for his real estate broker’s license as an employee of WFIC and ran most of his real estate transactions through WFIC’s trust account. WFIC also had other real estate agents working for it. These business activities are sufficient to convince us that WFIC was not a sham and should be recognized as a corporate entity separate from petitioner. See id.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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