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On May 4, 1988, White Star elected to be taxed as an S corpora-
tion. At the time White Star was formed, the following individu-
als were appointed to the offices indicated: Mr. Olbres as
president, Ms. Olbres as treasurer, and Manuel L. Olbres as vice
president.
In addition to designing and fabricating the exhibits,
Design Consultants and/or White Star arranged for certain busi-
nesses to perform auxiliary services (auxiliary services) for
their clients including, inter alia, transporting the exhibits,
setting up the exhibits, hiring on-site personnel at trade shows,
electrical work, floral arranging, and telephone services.
During 1986, Design Consultants and/or White Star used, inter
alia, Greyhound Exposition Services (Greyhound) for certain
auxiliary services, and during 1986, 1987, and 1988, they used,
inter alia, Mayflower Transit, Inc. (Mayflower), to perform those
services.
From sometime in 1983 through the years at issue, Design
Consultants was located in North Berwick, Maine. By around 1985,
it had approximately 20 to 24 employees. Mr. Olbres' responsi-
bilities for Design Consultants consisted of designing, ordering
materials for, supervising the setting up of, selling, and
pricing the exhibits. At all relevant times, Ms. Olbres, who
spent time caring for petitioners' children, did all of the
bookkeeping for Design Consultants and White Star.
During 1986 and 1987, clients of Design Consultants paid it
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