Winston Knauss - Page 3

                                        - 3 -                                         
          petitioner’s wholly owned S corporation, Winston Development,               
          Inc., overstated deductions on its 1995 Federal income tax return           
          by $54,802; (6) whether there was an underpayment of tax in 1991;           
          and (7) whether the underpayments of tax in 1991, 1994, 1995,               
          1996, and 1997 were due to fraud.                                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are incorporated            
          into our findings by this reference.                                        
               Petitioner was a resident of Ft. Lauderdale, Florida, when             
          the petitions were filed.                                                   
          Petitioner’s Background                                                     
               Petitioner is a high school graduate.  He initially held a             
          variety of construction jobs before becoming trained to be a                
          construction project estimator.                                             
               In 1968, petitioner started a demolition business that he              
          operated successfully for 20 years.  His business interests grew            
          to include apartment buildings, a hotel, and a country club.  In            
          1988, petitioner organized Winston Development, Inc. (WDI),3 an             
          S corporation, to build and sell condominiums in Indiana.  At all           
          relevant times, petitioner owned 100 percent of the stock of WDI.           
               In the mid-1980s, petitioner also became successfully                  



               3 The parties have stipulated that the name of the                     
          corporation was “Winston Development, Inc.”, though the                     
          corporation filed its tax returns as “Winston Development Corp.”,           
          and it is frequently referred to in the record by that name.                




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