Summit Sheet Metal Co. - Page 16

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          North County Builders, which were businesses other than                     
          petitioner.  Hanson testified that he worked about 25 hours a               
          week for petitioner.  Searing testified that he worked for                  
          petitioner from 2 to 10 hours a week.  Respondent contends that             
          petitioner paid its officers exclusively for services performed             
          for petitioner.                                                             
               We agree with respondent.  Petitioner's interrogatory                  
          answers conflict with Hanson's and Searing's testimony.  In                 
          supplemental interrogatory response for petitioner, Chasin stated           
          that Searing and Hanson "rendered services for petitioner based             
          upon an 8-hour day for 50 weeks per year."  The supplemental                
          response suggests that the officers provided substantial services           
          for petitioner.  Chasin testified that the supplemental response            
          included services for business ventures other than petitioner.              
          Chasin's explanation is contrary to the language in the                     
          supplemental response, which states that the services were for              
          petitioner.                                                                 
               North County Builders had five owners, including                       
          petitioner's three officers.  It is implausible that petitioner             
          would pay salaries that North County Builders owed.                         
               Petitioner's board of directors adopted written resolutions            
          which stated that petitioner declared the bonuses because its               
          officers contributed substantial services to petitioner.                    







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