Samuel T. Seawright and Carol A. Seawright - Page 3




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                                  FINDINGS OF FACT                                    
               The parties have stipulated some of the facts, which we                
          incorporate herein by this reference.                                       
          Petitioners                                                                 
               Petitioners are married.  When they filed their petition,              
          they resided in Columbia, South Carolina.                                   
          Columbia North East Used Parts                                              
               Petitioner Samuel T. Seawright (Samuel) owned and operated a           
          family business known as Columbia North East Used Parts                     
          (Columbia), located on Hardscrabble Road in Columbia, South                 
          Carolina.  Samuel was the primary laborer for Columbia,                     
          petitioner Carol Seawright (Carol) was the record-keeper, and               
          petitioners’ son, Monty Seawright (Monty), worked with Samuel at            
          Columbia on weekends.                                                       
               Columbia began operations in 1977, when Samuel paid about              
          $2,000 for five junked cars.  Petitioners owned a 1978 Ford truck           
          with a wrecker boom in the bed.  Samuel used the truck to pick up           
          and haul away items such as appliances, scrap metal, and junked             
          vehicles.  Samuel did not charge for the hauling service.                   
               Petitioners stored the junked vehicles and other hauled-away           
          items at their scrap yard on Hardscrabble Road.  Samuel rebuilt             
          some of the junked vehicles to sell.  Petitioners salvaged and              
          sold used parts from some of the junked vehicles.                           






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Last modified: May 25, 2011