Before finding that the taxpayer was a de facto director of a corporation that had never been organized on the basis that the taxpayer along with the other major shareholder were the directing minds of the corporation, Paris J. stated (at pp. 3551):
"... where a corporation operates without having been properly organized and the only director of record plays no part in running the corporation, those persons who take it upon themselves to direct the affairs of the company may be held to be de facto directors, whether or not they have explicitly represented themselves as directors to any third party. The essential question is whether those individuals have, in fact, taken on the role of director of the corporation."