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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners, Frederick and Catherine
Harrison, were husband and wife and resided in Marlton, New
Jersey, at the time they filed their petition in the instant
case. On January 16, 1994, Catherine Harrison died, and her
estate was substituted as a petitioner.
During 1989, petitioner Frederick G. Harrison owned and
operated three trucking and solid waste removal businesses in
Pennsylvania and New Jersey. The waste removal business in New
Jersey was a family owned business that petitioner started over
20 years ago. The waste removal business in Pennsylvania was
also a family business run by petitioner and his son. The third
business, consisting of trucking and waste disposal, was operated
by Penn Foundry, Inc. (Penn). Petitioner owned one-third of
Penn. Petitioner's son was also an owner of Penn. The trucking
and waste management businesses were considered by Mr. Harrison
to be his “working companies”, and they were generally
profitable. Mr. Harrison was around 65 years old in 1989.
Prior to 1989, Mr. Harrison owned a one-quarter interest in
a trash transfer station in Philadelphia, Pennsylvania, known as
LaForge, Inc. LaForge was sold in 1988 to a public company for
$4.8 million; Mr. Harrison's share of the proceeds was worth
approximately $1.2 million and was paid in stock.
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