In Uncategorized on 06/27/2019 at 16:02

No, not a remake of Gene Roddenberry’s never-ending story. This is the next generation of tax dodgers, Troy K. Dixon, 2019 T. C. Memo. 79, filed 6/27/19, who gets nailed from some, but not all, of the TFRPs from his parents’ now-defunct staffing agencies.

His parents are James and Sharon Dixon. Their tale is told in part in  my blogpost “The Great Dissenter – Redivivus,” 9/3/13.

Troy started from the bottom.

Judge Paris: “Despite his being established as the sole director and president of the corporation on paper, petitioner initially worked under the control and direction of his parents.  Petitioner was directed to work on third-shift labor crews, drive forklifts, and do other ‘dirty jobs’ while his parents actively managed the corporation. He worked at locations offsite from the corporate office.  Initially he had meetings with clients and focused on the “labor side” of the business.  Later he became more involved in sales and spent more time in the corporate office.

“In 2005 petitioner became the safety coordinator for the corporation and handled some sales.  Petitioner continued to work on safety and sales offsite and checked in with the corporate office in the mornings and evenings.  When he was at the corporate office, he would often have a stack of documents to sign.  He did so without reviewing them.  Occasionally petitioner checked the mail and made bank deposits, but primarily he left the mail for his parents to open and review.” 2019 T. C. 79, at p. 4.

But he was being groomed for the C-suite. And when he got there, with signature over accounts and hire-fire power, he didn’t bother paying a couple million dollars’ worth (hi, Judge Holmes) of FICA-FUTA-ITW for fifteen (count ‘em, fifteen) quarters.

Troy loses his CDP, and Judge Paris sustains.


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