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FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts, supplemental stipulation of facts, and the
exhibits attached thereto are incorporated herein by this
reference.
Petitioners William C. and Elaine Gaskins (the Gaskins) and
petitioners Pasquale T. and Sabina A. Quinn (the Quinns) resided
in Minersville, Pennsylvania, at the time they filed their
respective petitions. Their cases have been
consolidated for trial, briefing, and opinion.
Petitioners' Business Activities
Prior to 1968, William C. Gaskins (Mr. Gaskins) worked as a
roofer in the Philadelphia and Delaware area. While working in
Philadelphia for the roofers' union, Mr. Gaskins worked for a
John McCullough. From 1968 until 1975 or 1976, Mr. Gaskins owned
and operated his own roofing business known as Minersville
Roofing and Sheet Metal Company (the first roofing company).2
The business address was 142 Sunbury Street, Minersville,
Pennsylvania. Pasquale T. Quinn (Mr. Quinn) worked for the first
roofing company. This company fell behind in its payments of
withheld employment taxes to the Internal Revenue Service (IRS).
Mr. Gaskins was also the subject of a criminal investigation
with respect to these employment taxes but was never charged.
2Paragraph 13 of the parties' stipulation of facts contains an
incorrect name for this first roofing company. The Court relies upon
Mrs. Gaskins' testimony as to the correct name of the first company.
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