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before the IRS during those years. RSC timely filed employment
tax returns for 2001-04. Petitioner signed all of those
employment tax returns. RSC paid JRC $192,500 for services that
petitioner performed in 2001.
2. Consulting for Business, Inc.
Petitioner’s wife and two children owned a business called
Consulting for Business, Inc. (CFB).3 CFB provides marketing
activities (e.g., direct mail services) to JRC and RSC.
Petitioner has been president of CFB since its inception around
1995.
C. Petitioner’s Illness
In June 2002, petitioner sought treatment at the Mayo Clinic
for pain in his left leg and his back. The pain worsened in July
2002. He had difficulty walking in August 2002. Petitioner was
soon diagnosed with multiple myeloma, which he was told is an
incurable blood disorder. He received radiation therapy 22 times
over a 45-day period beginning in September 2002. Petitioner
changed medications several times because he had adverse
reactions. From August 2002 to April 2004, the medication
affected petitioner’s personality and caused petitioner to have
difficulty sleeping, bending, walking, and traveling.
3 Apparently petitioner was not a shareholder of CFB. Exh.
18-P, General Ledger for Consultants for Business, Inc., refers
to petitioner’s wife, but not petitioner, as a CFB shareholder.
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Last modified: May 25, 2011