3
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year at issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Scottsbluff, Nebraska, when she filed
the petition. Scottsbluff is in Scotts Bluff County.
Petitioner has a bachelor of science degree from Oregon
State University. She worked in Denver as a medical research
chemist for 4 years before she married Stanko. In 1973,
petitioner and Stanko were married, and petitioner moved to
Gordon, Nebraska. Petitioner quit working outside the home. She
and Stanko had four children.
B. Rudy Stanko and Stanko Packing Co.
1. Stanko’s Businesses
Stanko was the president and sole shareholder of Stanko
Packing, an accrual basis meat packing corporation doing business
in Gering, Nebraska. Stanko's cousin, Henry Stanko, had been a
coowner of Stanko Packing until Stanko bought his stock sometime
after December 1980.
R.G. Stanko Express, a subsidiary of Stanko Packing, was a
trucking company. The School of Gymnastics, Inc., was also a
subsidiary of Stanko Packing. Stanko owned a meat packing plant
in Denver, Colorado, called Cattle King Packing Co. Henry Stanko
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