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qualified personal service corporation under section 448(d)(2),
and therefore subject to the flat 35-percent tax rate pursuant to
section 11(b)(2).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner’s principal place of business was Menomonee
Falls, Wisconsin.
Petitioner is a Wisconsin corporation licensed by the State
and engaged in the business of providing geotechnical testing and
engineering services. Petitioner is described as a geotechnical
testing and engineering firm on the corporate annual reports
filed with the State of Wisconsin. Petitioner also files, at
least biannually, a report with the Architects and Engineers
Registration. During the taxable years in issue, petitioner
employed two engineers, Allan F. Huseth (Mr. Huseth) and Jeffrey
Smith (Mr. Smith), and approximately ten non-engineering
personnel, including technicians and clerical staff. Mr. Huseth,
the president of petitioner and 100-percent owner of petitioner’s
stock during the years in issue, is a registered professional
engineer in the State of Wisconsin since 1971, with a bachelor of
science degree in civil engineering and a master of science
degree with a specialty in soil mechanics and highway
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