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Business Activities
During the years in issue, petitioner was involved in a
number of business activities, as follows: (1) Petitioner's law
practice, (2) Hall Farms, (3) Concordia Property, Inc.
(hereinafter sometimes referred to as Concordia), (4) Six
Drilling Co. (hereinafter sometimes referred to as Six Drilling),
(5) Stroud America Land Co., Inc. (hereinafter sometimes referred
to as Stroud Land), (6) Stroud America Builders, Inc.
(hereinafter sometimes referred to as Stroud Builders), (7)
Preferred Security Systems, Inc. (hereinafter sometimes referred
to as Preferred), (8) Brazos Drilling Co. (hereinafter sometimes
referred to as Brazos), (9) Empire Drilling Co. (hereinafter
sometimes referred to as Empire), (10) Paramount Valley Angus
Farms, Inc. (hereinafter sometimes referred to as Paramount
Farms), (11) Service Rig Co. (hereinafter sometimes referred to
as Service Rig), (12) Paramount Oil Co. (hereinafter sometimes
referred to as Paramount Oil), and (13) Petron Energy, Inc.
(hereinafter sometimes referred to as Petron).3 All of these
3Respondent proposes a finding of fact that petitioner was
involved in activities with PVAF, Inc., during the period 1982-
1986. Petitioner testified that his tax returns for this period
may have shown, as expenses, interest of PVAF, Inc., or the cost
of items that had been bought through the use of PVAF, Inc.
However, the parties have stipulated that PVAF, Inc., was
incorporated on August 18, 1988, and this incorporation date is
corroborated by a stipulated report from the Oklahoma Secretary
of State’s office. We follow the stipulation and stipulated
exhibit rather than petitioner’s testimony and the unobjected-to
proposed finding of fact, and do not include PVAF, Inc., among
the 1982 through 1986 corporations.
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