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FINDINGS OF FACT
During 1989 through 1994, petitioner was engaged in business
as a painting contractor, painting new and existing gasoline
service stations. He did business under the name PAINT-SER LTD.,
and he performed the painting services himself. During the years
1989 through 1994, petitioner, d.b.a. PAINT-SER LTD., performed
painting services for Shell Oil Co. (Shell), for which Shell paid
him, as follows:
Year Amount
1989 $51,619.64
1990 84,832.88
1991 35,919.48
1992 63,163.81
1993 64,645.53
1994 46,162.61
During the years 1990 through 1994, petitioner, d.b.a.
PAINT-SER LTD., performed painting services for Town and Country
Contractors, Inc. (Town and Country), for which Town and Country
paid him, as follows:
Year Amount
1990 $27,807.20
1991 49,442.09
1992 17,821.04
1993 1230.64
1994 8,091.17
1On brief, respondent states that the amount of petitioners'
income from Town and Country for 1993 is $203.64. However,
respondent's schedules accompanying the brief indicate that
petitioners' income is $230.64. After reviewing the record, it
is apparent that the correct amount of income received from Town
and Country by petitioners in 1993 is $230.64.
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