Robert T. and Mary F. Gow - Page 3




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               All section references are to the Internal Revenue Code as in            
          effect for the years in issue.  All Rule references are to the Tax            
          Court Rules of Practice and Procedure.  All dollar amounts are                
          rounded.                                                                      
                                   FINDINGS OF FACT                                     
               Some of the facts have been stipulated and are so found.  The            
          stipulations of facts, stipulations of settled issues, and attached           
          exhibits are incorporated herein by this reference.                           
          Background                                                                    
               Petitioners, husband and wife, resided in Norfolk, Virginia,             
          at the time they filed their petition.                                        
               Kay F. Gow (Dr. Gow) earned a doctor of education (Ed.D.)                
          degree from Virginia Tech., specializing in business education.  As           
          part of her curriculum she took courses in accounting.  Before                
          1983, she taught and supervised a business education program at a             
          public high school in Virginia.  At the time of trial, Robert T.              
          Gow (Mr. Gow) was a retired civil service employee.                           
          Williamsburg Vacations, Inc. (WVI)                                            
               WVI was incorporated under the laws of Virginia on July 21,              
          1983.  In November of 1986, WVI became a partner in a joint venture           
          known as Powhatan Associates.  (The other two members of the joint            
          venture were Offsite International (Offsite) and Bush Construction            
          Co. (Bush).  None of the joint venturers were related; each held a            
          one-third interest in Powhatan Associates.)  During the years in              
          issue, WVI’s sole income-producing property was its indirect                  




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