Earl E. Cloud, Jr. and Sheila S. Cloud - Page 3




                                        - 3 -                                         
                                  FINDINGS OF FACT                                    
               The parties have stipulated some of the facts, which are               
          incorporated in our findings by this reference.  Petitioners                
          resided in Huntsville, Alabama, when the petition was filed.                
          Petitioners filed joint Federal income tax returns for each of              
          the years at issue.                                                         
               In 1983, petitioner husband (hereinafter petitioner) and his           
          father incorporated Pacer Industries, Inc. (Pacer), an Alabama              
          corporation.  Petitioner was the principal stockholder and                  
          managed the business, while also engaging in the practice of law.           
          Pacer manufactured vending machines in Fyffe, Alabama, employing            
          on average 20-30 persons and servicing as many as 30-40                     
          customers.                                                                  
               In early 1987, Pacer ceased operations in Fyffe when the               
          City of Fyffe locked the doors and put a lien on the building               
          because Pacer was delinquent in paying its rent.  In September              
          1987, some of Pacer’s manufacturing equipment was moved from                
          Fyffe to a building then being leased by Idea Technologies, Inc.            
          (Idea Technologies), in Huntsville, Alabama.  In late 1987,                 
          petitioner negotiated with John Ford, who was general manager of            
          one of Pacer’s customers, Management Marketing Consultants, to              
          manufacture 600 to 800 vending machines.  Stan Rowe was hired to            
          oversee a crew of several contract-basis workers and an Idea                
          Technologies employee.  After delivery of approximately 400                 






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