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Mr. Haymond left the data processing field and began to devote
his business efforts to power production. Petitioner Janis S.
Haymond (Mrs. Haymond) has spent most of her life raising 10
children. Her formal education beyond high school consisted of
some college courses on the subjects of early childhood and
psychology taken periodically. She was not involved in her
husband's business activities, except as described below.
InTex Fuels and Chemicals Corporation (InTex) was an S
corporation during the taxable year 1990. Mr. Haymond owned 100
percent of the stock of InTex and served as its president. The
board of directors of InTex consisted of petitioners and Joseph
Winther; these individuals were also InTex's officers. Mrs.
Haymond's role as a director and an officer was to sign documents
as needed; she did not participate in the operations of InTex or
in its decision making.
InTex entered into a joint venture with Bonneville Pacific
with respect to the Lehi Co-Generation Plant project (the
project). InTex owned 49 percent of the project and Bonneville
Pacific owned 51 percent. As a result of disagreement between
Mr. Haymond and Bonneville Pacific, sometime in 1989, InTex
transferred its interest in the project to Bonneville Pacific in
exchange for Bonneville Pacific stock (the stock). Bonneville
Pacific also agreed to redeem the stock in 1990 at a set price
that exceeded the value of the stock at the time of the exchange.
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