- 3 - All section references are to the Internal Revenue Code and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulation of facts is incorporated in our findings by this reference. Petitioners Richard C. (Richard) and Hattie M. Martin, husband and wife, and petitioners William L. (William) and Sylvia L. Martin, husband and wife, resided in Rolling Hills Estates, California, at the time they filed their respective petitions in this Court contesting respondent's determinations. Richard and William are brothers. Richard is a principal shareholder of a corporation that is one of the largest commercial drywall, framing, and plastering contractors in the Los Angeles area. For many years, he had an interest in car racing. Formation of Cola, Inc. In 1988, Richard and Raul Negrete (Raul) (formerly, the general manager of L.A. Billet, a manufacturer of race car crankshafts) decided to form a corporation that would engage in the business of manufacturing automotive crankshafts for race cars (the business). Both agreed to contribute $100,000 to the corporation. On June 22, 1988, Richard's attorney, Mark A. Treadwell, of Mantalica & Treadwell, filed the necessary corporate documentationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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