- 27 - Elliotts, Inc. v. Commissioner, 716 F.2d at 1246; see E. Wagner & Son, Inc. v. Commissioner, 93 F.2d 816, 819 (9th Cir. 1937). Petitioner was a relatively small label and printing company that grossed more than $4 million annually for its 1988 through 1990 fiscal years. It had secured itself a nice market niche in supplying certain custom-designed products to a number of high- technology companies, thus enabling it to earn high profit margins on its product sales. Moreover, as petitioner's directors correctly anticipated in June 1990, its recently developed clean room labels would produce significant profits and give petitioner a competitive advantage in future years. From 1991 through 1996, the new clean room labels helped reverse the slight decline in business petitioner experienced during its 1989 and 1990 fiscal years. Also, Mr. Martin's 100-percent stock interest in petitioner was subsequently appraised by a business valuation company to have a fair market value of $9.25 million, as of October 25, 1991. In years after 1990 and 1991, the labels were probably the single most important factor in spurring petitioner to even greater sales and profitability. All in all, from its inception through the 1990 fiscal year, petitioner has been an extremely well managed and profitable company. It had a very lean management team and by the 1990 fiscal year enjoyed an excellent reputation in the labelPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011