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all of the arrangements and devising the plans for the
development of new projects before and during the taxable years
in issue.
Jody began working for the corporation at the beginning of
1993. He served as its vice president and worked as its overall
manager of operations. As part of his management responsibility,
he coordinated the hiring of independent contractors who were to
perform construction work at the project sites. Jody also worked
as the lead carpenter on many of the homes built during 1993 and
1994.
Prior to 1993, Jody had worked as a senior auditor for
Reliance Electric Company. He studied accounting at Ohio State
University and business administration at Xavier University,
including some courses in taxation.
David was a student during the taxable years in issue. At
the time of trial, he was attending medical school. He has never
worked for the corporation.
Michael owned 100 percent of the corporation's stock when it
was incorporated in 1982. In subsequent years, he caused the
corporation to issue 30 percent of the stock to be held by his
sons in varying amounts. During the taxable years in issue,
Michael, Jody, and David held the corporation's stock as follows:
Year Michael Jody David
1992 70% --- 30%
1993 70% 30% ---
1994 70% 30% ---
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