Crew III, J.
In 1994, petitioner and George Perk were the sole officers and shareholders of American Futures Group Holding Company, Inc. (hereinafter AFGH). Petitioner owned 48% of AFGH and served as its treasurer and secretary. AFGH, in turn, owned 100% of American Futures Group, Inc. (hereinafter AFG), and petitioner served as its president.
During an audit of withholding taxes due from AFG, the Division of Taxation reviewed both AFG's and AFGH's federal...
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