Petitioner and two others, Otto Luthi and Paul Decelle, owned and operated the Hermitage Restaurant, Inc. Petitioner operated the restaurant and served as maitre d'; Luthi served as bartender; and Decelle, because of his prior bookkeeping experience in the restaurant business, served as financial officer, which included the payment of bills, signing of checks and the preparation and filing of all tax returns.
Prior to June 1, 1978, Decelle...
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