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conversion company on the West Coast; nationwide, it ranked
seventh or eighth. Petitioner’s success was largely due to
Atkinson’s keen administrative, sales, and marketing techniques.
The Construction of the Carnelian Bay Residence
On November 7, 1983, the Atkinsons purchased a residential
property in Carnelian Bay, California, for $550,000 (Carnelian
Bay property). Carnelian Bay is located on the north shore of
Lake Tahoe, approximately 5 miles from Tahoe City. The Atkinsons
purchased the Carnelian Bay property with the intent to live and
retire there. Because the Atkinsons planned to build a new home
on the Carnelian Bay property (Carnelian Bay residence), the
Atkinsons did not immediately relocate to Carnelian Bay.
In 1984, petitioners hired James Woodle (Woodle) to
supervise construction of the Carnelian Bay residence and
improvements to the Carnelian Bay property. Construction began
in 1985 and lasted 16 months. In July of 1986, the Atkinsons
moved into their new 4,000-square-foot-home.
Woodle’s duties included ordering construction materials and
recruiting construction workers necessary for the completion of
the Carnelian Bay residence. Woodle paid for small expenditures
on construction materials from a checking account established by
Atkinson with a local bank. Most of the larger expenditures on
construction materials and the wages of the construction workers
(construction expenses) were paid directly by petitioner.
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