Roger L. and Geraldine Williams - Page 3

                                         -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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