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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect in the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
I. FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner is a Florida corporation the principal place of
business of which was in St. Augustine, Florida, during the years
in issue and when it filed the petition.
A. Robert E. Ward, Jr.
Robert E. Ward, Jr. (Ward), was raised on a dairy farm in
Eufala, Alabama. He attended Auburn University. He was married
around 1962. He and his family moved from Eufala to Hastings,
Florida, in 1965. In Hastings, he worked as a sales
representative for an agricultural chemical company. In 1975,
Ward decided to start his own business of selling supplies to
farmers, in part because he had become close to the farmers
there. Ward began by selling fertilizer from the back of a
truck. He did not have an office for the first 3 years. Ward
borrowed money to keep his business going.
Ward's son, William David Ward (W.D. Ward), began to work
for Ward in 1983. W.D. Ward was petitioner's warehouse manager.
Ward and his family owned an interest in a farm in Alabama.
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