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husband owned in the aggregate 49 percent, of the stock of
Crystal & Ryan, Inc.
In 1994, petitioners organized The Mifsuds, Inc., an S
corporation, for the purpose of operating a restaurant known as
Rams Horn. During that year, petitioners owned 100 percent of
the stock of The Mifsuds, Inc.
When Paul & Joe, Inc., first began operating Spring Hill
restaurant, Mr. Mifsud and Mr. Mamo, his son-in-law, worked
principally as cooks, Ms. Mifsud operated the cash register, and
occasionally Ms. Mamo operated the cash register and served as a
hostess in the dining room of that restaurant.
Around 1983, Mr. Mamo had an automobile accident, was forced
to quit working at Spring Hill restaurant, and did not return to
work there until around 1985 or 1986. When Mr. Mamo returned to
work at Spring Hill restaurant, he worked at the cash register
and served as a host in the dining room. Mr. Mamo stopped
working at Spring Hill restaurant around October 1991 and started
working at Breakfast Club of 7 Hills, which was owned by Nichole
& Eric, Inc. Thereafter, he had no further involvement in the
operations of Spring Hill restaurant, although he and Ms. Mano
continued to own 40 percent of the stock of Paul & Joe, Inc.,
which owned that restaurant.
After Mr. Mamo's accident in 1983, Mr. Mifsud stopped
working as a cook at Spring Hill restaurant and began, and
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