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During the years 1981 and 1982, John Cidulka was involved in
nearly every aspect of SOAI, including accounting, sales,
construction, collection of accounts, leases, site selection,
construction of signs, and supervision of employees. In 1981,
the total number of employees of SOAI was 25. After January 25,
1982, no member of the Cidulka family, other than John Cidulka,
was employed by SOAI, except for Lauren, who was employed on a
part-time basis in 1982 and 1983, for which she received $1,200
and $2,300, respectively.
In 1981, SOAI had a profit-sharing plan. The formula for
contributions was 5 percent of earned payroll. John Cidulka
received only the pension benefits received by other employees,
but he did receive a company car and other related benefits.
The unaudited balance sheets of SOAI for its fiscal years
1977 through 1981 in summary show the following:
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