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section 6661.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
their petitions, petitioner’s principal place of business was in
Irwindale, California, and the Atkinsons resided in Carnelian
Bay, California.
Bernard Atkinson’s Professional Experience in the Automotive
Industry
From 1950 to 1959, after graduating from high school,
Bernard Atkinson (Atkinson) was employed at an automobile
dealership and a finance company specializing in automobile
loans. During that time, Atkinson supplemented his practical
knowledge of the automobile industry by studying automobile
mechanics and dealership management at the General Motors
Institute in Flint, Michigan.
From 1959 to 1968, Atkinson worked in General Motor’s
Pontiac Motor Division as a warranty clerk. In 1968, he
continued working in the automotive field by taking a position
with Trafco Corp. (Trafco) in Brown, Michigan. Trafco
manufactured recreational vehicles. In 1973, Compact Equipment
Co., a subsidiary of Trafco located in Southern California, hired
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