Sid Paul Ruckriegel - Page 4

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                                  FINDINGS OF FACT4                                   
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts, with attached exhibits, is incorporated by            
          this reference.                                                             
               At the time the petitions were filed, petitioner Sid Paul              
          Ruckriegel (Sid) resided in Peoria, Illinois, and petitioner Al             
          A. Ruckriegel (Al) resided in Terre Haute, Indiana.                         
          Sidal, Inc.                                                                 
               Sidal, an Indiana corporation, elected S corporation status            
          at the time of its organization in 1993 and retained that status            
          through December 31, 2000.  During that period, petitioners were            
          each 50-percent shareholders in Sidal.  Sidal operated                      
          approximately 50 fast food franchise restaurants throughout                 
          Indiana and part of Illinois during the 1997-2000 period.  From             
          its incorporation in 1993 through 2000, Sidal operated at a loss.           
          Sid and Al actively managed the Sidal restaurants.                          
          Paulan Properties Partnership                                               
               From its formation, in 1993, through December 31, 2000,                
          petitioners were each 50-percent partners of Paulan Properties              
          Partnership (Paulan), a general partnership governed by Indiana             


               4  To the extent that petitioners fail to object to                    
          respondent’s proposed findings of fact, or vice versa, we                   
          conclude that those proposed findings of fact are correct except            
          to the extent that the nonobjecting party’s proposed findings of            
          fact are clearly inconsistent therewith.  See Jonson v.                     
          Commissioner, 118 T.C. 106, 108 n.4 (2002), affd. 353 F.3d 1181             
          (10th Cir. 2003).                                                           




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