- 3 - Some of the facts have been stipulated and are so found. The stipulated facts are incorporated in our findings by this reference. FINDINGS OF FACT At the time petitioners filed their petition, they resided in Delafield, Wisconsin. Background From approximately 1956 until 1987, petitioner was a 50- percent shareholder and vice president of ARCO Industries (ARCO), a Wisconsin corporation that manufactured chemicals for the swimming pool industry. Carl Ulrich, who served as president of ARCO, owned the remaining 50-percent interest in ARCO. In 1987, petitioner and Mr. Ulrich sold their interests in ARCO to Sowhite Chemical Corp. (Sowhite Chemical), another Wisconsin corporation in the same business as ARCO, and petitioner then retired. Sowhite Chemical agreed to pay the purchase price for petitioner's and Mr. Ulrich's interests in ARCO through monthly installments over an 11-year period. The amount of petitioner's monthly installment was approximately $7,488. In October 1993, Sowhite Chemical filed for bankruptcy protection and stopped making payments to petitioner. IRA Distributions When petitioner sold ARCO, he rolled his qualified pension plan into an individual retirement account (IRA). In 1989,Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011