Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 7




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               Also throughout the years in issue, petitioner worked 40 or            
          more hours per week at SRMC and received a salary for his                   
          services.  Petitioner Mrs. Wesinger was likewise employed by SRMC           
          during these years and was compensated for her work as the Human            
          Resources manager.  However, during the period following                    
          petitioner’s decision to embark upon a ranching venture, SRMC               
          began experiencing business reverses.  An audit by the IRS and a            
          subsequent bank audit disrupted the company’s operations and                
          culminated in 1993 with the bank calling its outstanding loan to            
          SRMC of $2.8 million.  SRMC was forced to seek sources of short-            
          term credit and eventually paid the debt in 1997.  Meanwhile, in            
          1994, petitioner began the process of changing SRMC’s primary               
          line of business from custom hardware to Internet-related                   
          software.  Several patents dealing with this software either have           
          been issued to petitioner or are pending, and petitioner expects            
          the new technology to generate a profit in the future.  As of               
          early 1999, SRMC (now known as NES) was not making money.                   
               Yet another event affecting petitioners’ economic situation            
          during the years at issue was a hurricane which damaged property            
          they held in Hawaii.  The damage occurred in late 1992 and                  
          necessitated that time be spent in Hawaii during the following              
          winter, but the situation was largely resolved by the spring of             
          1993.                                                                       








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