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All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference.
BDC is a Minnesota corporation, whose primary place of
business was in Bemidji, Minnesota, when it filed its petition in
these cases. When they filed their petition, the Langdons
resided in Bemidji, Minnesota.
A. BDC and the Wholesale Beer and Beverage Distribution Business
In 1933, Mr. Langdon's father founded BDC. BDC grew to be
the largest wholesale beer distributor in northern Minnesota,
enjoying an estimated 53 percent of the wholesale beer sales in
its geographic market by 1990.
Mr. Langdon became part owner of BDC in 1943 and began full-
time employment with the company in 1945. He operated the
business for 46 years until he sold it to Bravo.
Since its founding, BDC maintained its business offices and
warehouse in Bemidji, the county seat of Beltrami County. It had
customers in seven counties in northern Minnesota, including all
of Beltrami, Clearwater, and Hubbard Counties and parts of Cass,
Itasca, Koochiching, and Polk Counties. Of its 242 customers
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Last modified: May 25, 2011