Stuart and Betsy Bobry, et al. - Page 3

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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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