- 3 -
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petitions in these cases were filed, Allied maintained
its principal place of business in Solomons, Maryland, and
petitioner resided in Solomons, Maryland. Petitioner was born in
1932.
Allied
In 1973, petitioner retired from the Navy. While in the
Navy, petitioner's primary duties were underwater construction,
underwater explosives, and deep-sea diving. Prior to his
retirement, petitioner formed Allied as a partnership. Allied
was incorporated in 1986. During the years in issue, Allied was
in the business of general waterfront construction, including
constructing residential bulkheads, piers, and marinas. Allied
was a cash basis taxpayer during the years in issue.
In 1988 and 1989, petitioner was president and general
manager of Allied and owned 25 percent of Allied's stock. His
duties included locating work for Allied, scheduling work
assignments, and obtaining the requisite permits required for
waterfront construction. Petitioner also used his skills as a
pilot while working for Allied.
For liability insurance purposes, Allied's accounting system
for receipts was divided into two portions: "services income"
and "other income". Services income included moneys derived from
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011