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(2) Whether the administrative and litigation costs claimed
by petitioners are reasonable. In light of our holding as to the
first issue, we need not address this second issue.
Neither party requested an evidentiary hearing, and the
Court concludes that such a hearing is not necessary for the
proper disposition of petitioners' motion. See Rule 232(a)(2).
We therefore decide the matter before us on the basis of the
record that has been developed to date.
Background
Petitioners resided in Oklahoma at the time that the
petitions were filed with the Court.
Petitioners Ronald D. Pittman (Pittman), Douglas W. Kemp (D.
Kemp), and Paul W. Kemp (P. Kemp) are shareholders of Industrial
Coil, Inc. (IC), an S corporation, and each owns 33.33 percent of
its stock. IC was founded in 1982 as a partnership of Pittman,
D. Kemp, and P. Kemp. An election was made on January 1, 1989,
to convert IC into an S corporation.
IC manufactures electric coils according to specifications
provided by its customers. The specifications include the
dimensions, types of materials to be used, and other requirements
necessary to manufacture the coils. IC purchases materials
locally for each job depending on customer specification.
Approximately 90 percent of IC's jobs are completed within 3
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