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FINDINGS OF FACT
Some facts have been stipulated and are so found.
Petitioners resided in Pittsford, New York, when their petitions
were filed.
During the years in issue, petitioners Stuart Bobry, Harold
Bobry, and Michael Bobry (Harold and Michael are sons of Stuart
Bobry) owned all of the stock in Lyell Metal, an S corporation,
as follows:
Percentage of Stock Ownership
Year Stuart Harold Michael
1989 75.50 12.25 12.25
1990 52 24 24
1991 52 24 24
1992 52 24 24
During 1989 through 1992, Lyell Metal was engaged in the
scrap metal recycling business in the vicinity of Rochester, New
York. Lyell Metal purchased scrap metal from large, industrial
users of scrap metal, from small businesses, and from
individuals.
In the Rochester, New York, metropolitan area, much of the
trade in scrap metal occurs by way of cash transactions.
Industrial companies from which large quantities of scrap metal
are purchased will often accept payment by check, while most
small businesses and individuals from whom scrap metal is
purchased accept payment only by cash.
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Last modified: May 25, 2011