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B. Swirl, Inc.
Swirl was incorporated in South Carolina on March 4, 1954.
Swirl's sales and executive offices were in New York City. Swirl
owned 100 percent of the voting stock of Swirl Sales, Inc.
(Swirl Sales), and Easley Realty Co. (Easley). Swirl Sales was
incorporated in New York. Easley was incorporated in South
Carolina. Swirl and Swirl Sales designed, manufactured, and
distributed women's robes, loungewear, and intimate apparel which
were sold to specialty stores in the United States, Canada,
Japan, Great Britain, Germany, France, and the Middle East.
C. Petitioner's Employment By and 50 Percent Ownership
Of Swirl
Petitioner began to work in the sales and executive offices
of Swirl in 1970. Petitioner became assistant to the president
in 1972, vice president in 1975, and executive vice president and
co-chief executive officer in 1979. Petitioner and his brother
began to manage Swirl in 1975.
Petitioner and his brother each acquired 50 percent of
Swirl's stock in 1979. Petitioner became Swirl's president and
co-chief executive officer in 1983. Almost all of petitioner's
income from 1970 to 1988 was from Swirl.
Petitioner and his brother obtained a 50-percent-undivided
interest in the Easley Plant and a 40-percent-undivided interest
in Ware Place at a date not specified in the record. The Easley
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