Stephen D. Podd - Page 5

                                        - 5 -                                         
               5.  whether petitioner Victor I. Podd was a resident of the            
          United States during 1990; and                                              
               6.  whether petitioners are liable for certain additions to tax        
          and penalties as determined by respondent.                                  
               For convenience and clarity, we have divided our opinion into          
          separate segments.  The first segment sets forth general findings of        
          fact applicable to all of the issues in the instant case.  Each of          
          the segments following our general findings of fact discusses one of        
          the separate issues set forth above and sets forth our findings of          
          fact and opinion concerning the respective issue.                           
          I.  General Findings of Fact                                                
              Some of the facts have been stipulated for trial pursuant to           
          Rule 91.  The stipulations of facts are incorporated herein by              
          reference, and they are found accordingly.                                  
               At the time its petition was filed, in the instant case,               
          Powertex, Inc. (Powertex) was a New York corporation.  Powertex's           
          principal corporate office was located at Rouses Point, New York.           
          At the time they filed their petitions in the instant case,                 
          petitioners Victor T. and Julia Podd resided in Mount Royal, Quebec,        
          Canada; petitioner Stephen D. Podd resided in North Hero, Vermont;          
          and petitioner Victor I. Podd resided in Boca Raton, Florida.               
               A.  Founding of Powertex                                               
               Powertex was incorporated under the laws of the state of               
          Vermont in 1977 by petitioner Victor T. Podd (Mr. Podd), his wife           
          petitioner Julia Podd (Mrs. Podd), and his brother Alexander Podd.          

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011