- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011