-3-
of which will depend upon our disposition of the issues
enumerated above.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioners resided in Seattle, Washington, at the time
that their petition was filed with the Court.
Petitioner Roger L. Williams (petitioner) began operating a
shoeshine business in 1990 at the Holiday Inn in Renton,
Washington. Some time thereafter, but prior to the year in
issue, petitioner moved his shoeshine business to the Red Lion
Hotel (Red Lion) in SeaTac, Washington.
The shoeshine stand at the Red Lion had two chairs and was
owned and maintained by the Red Lion. Petitioner paid the Red
Lion $43 per week for use of the stand. Petitioner paid the
rental in cash, and the Red Lion issued a receipt for the amount
paid. Petitioner gave the receipts to his wife, who kept the
records of his expenses.
On or about May 15, 1993, petitioner began operating a
second shoeshine stand at the South Satellite of the Seattle-
Tacoma International Airport (SeaTac Airport). SeaTac Airport is
located no more than a half-mile from the Red Lion.
Petitioner operated his shoeshine business at SeaTac Airport
pursuant to a month-to-month lease (Port lease) with the Port of
Seattle (Port). In contrast to Red Lion, the Port did not
provide petitioner with a shoeshine stand.
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