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1982, Gerald Mussman served as NITCO's vice president, and
petitioner Myrtis Mussman (Mrs. Mussman) served as its secretary-
treasurer. During the years in issue, Mr. and Mrs. Mussman and
Gerald Mussman were NITCO's only directors and officers.
During 1987 through 1989 and in prior and subsequent years
relevant to these instant cases, Mr. Mussman was the primary
decision maker at NITCO. He made all final major decisions
concerning NITCO's operation and how its earnings were spent.
Mr. and Mrs. Mussman have two sons, Rhys Mussman (Rhys) and
Kyle Mussman (Kyle). Rhys was born in 1956 or 1957; Kyle was
born in 1965 or 1966. Each son, at various times pertinent to
the instant cases, worked as a full-time employee of NITCO. They
also, at various times pertinent to the instant cases, left
NITCO's employ to pursue other business ventures for their own
accounts, including a cable television company business and
various cellular telephone company businesses.
NITCO's local telephone business has been a family-owned
and-operated business. The business was originally owned and
operated by Mr. Mussman's father. Mr. Mussman began working in
the business as a teenager in 1938. From about 1947 through the
time of the trial in the instant cases, Mr. Mussman worked as a
full-time employee in the business. Gerald Mussman left the
family business in 1947 when he took a job with AT&T.
When Mr. Mussman's father died in 1954, Mr. Mussman
inherited his father's NITCO shares. At various times since
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