Stephen F. Scofield and Nancy E. Scofield - Page 4

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          recycling business.  Lawrence McKee (McKee) was also associated             
          with Unidyne.  Unidyne stopped doing business in 1977.                      
               2.   Northeast Cellulose, Inc.                                         
               In 1977, petitioner (and apparently McKee) started a company           
          called Northeast Cellulose, Inc. (Northeast).  Northeast                    
          brokered, bought, and sold newsprint.  Northeast sold commercial            
          printing paper, magazine paper, and newsprint to retailers and              
          printers.                                                                   
               Petitioner was an officer and director of Northeast.  He               
          owned 50 percent of the stock of Northeast, a Massachusetts                 
          corporation.  Petitioner invested about $4,000 for his Northeast            
          stock.  McKee was Northeast's other 50 percent stockholder and              
          was president of Northeast.                                                 
               Petitioner worked about 25 hours per week for Northeast in             
          1978 and 1979.  Among his other duties, petitioner maintained               
          Northeast's customer and mill contacts.  Northeast did not pay a            
          salary to petitioner in 1979.1                                              
               Northeast earned a commission on its sales.  Paper mills               
          typically paid a commission to Northeast of 3 percent, after                
          freight and related costs.  At first, Northeast acted as a                  
          broker.  Eventually, however, it took title to the paper, which             
          required it to establish lines of credit.                                   



               1 The record does not indicate whether Northeast paid a                
          salary to petitioner in any other year.                                     




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