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I. FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Alpharetta, Georgia, when he filed the
petition in this case.
B. Eagle's Nest Homes and Timberline Building Systems
1. Formation, Ownership, and Tax Status of Eagle's Nest
Homes
In 1983, petitioner and Lawrence Gandolfi (Gandolfi)
incorporated Eagle's Nest Homes, Inc. (Eagle), in North Carolina.
Eagle sold panelized house kits; i.e., prefabricated houses which
were shipped to homesites to be assembled. Initially, Eagle's
offices were in Kannapolis, North Carolina. In 1987, Eagle moved
to Canton, Georgia. Gandolfi and petitioner each owned 50
percent of Eagle's stock before 1990. Petitioner became the sole
shareholder of Eagle in 1990.
Eagle was a C corporation before July 29, 1990. Eagle
elected to be an S corporation effective July 29, 1990. Eagle
had a short taxable year from July 29 to December 29, 1990.
2. Timberline Building Systems
Petitioner, Michael Goss (Goss), Gandolfi, and others formed
Timberline Building Systems (Timberline) in 1986. Goss was the
president of Timberline. Petitioner owned 50 percent of the
stock of Timberline. Timberline was an S corporation.
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