- 3 - Background Some of the facts and certain exhibits have been stipulated. The parties’ stipulations of fact are incorporated herein by reference and are found as facts in the instant case. Petitioner resided in St. Augustine, Florida, at the time the petitions were filed in the instant cases. Petitioner graduated from the University of Colorado in 1972 with a business degree, majoring in finance and minoring in economics. Petitioner is a licensed commercial real estate broker and has commercial real estate management experience. Petitioner failed to file federal income tax returns, make estimated payments, or pay the tax due for his 1999 through 2002 taxable years. During that time, petitioner was the sole shareholder and president of St. Augustine Self Storage, Inc. (company), an S corporation incorporated in 1986. When incorporated, the company had three shareholders, including petitioner. The company owns property located at 5 Willard Drive, St. Augustine, Florida (property). On August 6, 1986, the company executed a note in the amount of $1,225,000 (note) and, to secure the note, a mortgage encumbering the property. Petitioner did not provide any evidence that he is or has ever been personally liable to pay the note.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011