- 31 - years as of the beginning of petitioner’s fiscal year ended July 31, 1996. This factor favors respondent. E. Economic Conditions If general economic conditions are favorable, they may downgrade the extent of the employee’s effect on the company’s performance. Mayson Manufacturing Co. v. Commissioner, 178 F.2d 115, 119-120 (6th Cir. 1949), revg. and remanding a Memorandum Opinion of this Court. The record reflects the construction boom in Douglas County from 1990 through 1996. Indeed, with some help and guidance from Mr. Myers, Myers Foundations and Collins Concrete, two other foundation and flat work contracting companies that he helped establish, were able to operate successfully and obtain substantial business during 1995 and 1996. Although the construction boom in Douglas County contributed to petitioner’s profitability during these years, the record also reflects that petitioner was a well managed company whose work enjoyed an excellent reputation among builders and other construction industry people in the Denver, Colorado, area. This factor is neutral because petitioner’s financial success was not due merely to fortuitous economic conditions. Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. at 1158; Neils v. Commissioner, T.C. Memo. 1982-173.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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