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sidewalks, and the installation of utilities). The activities of
Highland’s real estate sales operation, which did business during
1996 as “Highland Realty”, included selling residential and
unimproved real estate.
During 1996, both petitioner and his brother worked full-
time for Highland. Petitioner provided services to both
Highland’s general heavy construction business and its real
property sales activity. For the former, he managed the
corporate office, secured construction projects, acquired land
for property development, ordered construction materials and
supplies and assured their timely arrival at construction sites,
and reviewed construction progress at construction sites. For
the latter, petitioner provided services as a real estate broker.
Petitioner is licensed as a real estate broker in the State of
Idaho.
Prior to 1996, Highland suffered a series of setbacks that
put it in a dire financial situation. The setbacks included a
cost overrun in excess of $1 million on a road job with the U.S.
Forest Service, a lengthy lawsuit involving the company’s
purchase of faulty equipment, and deliberate interference with
Highland’s work by an environmental group (Earth First) that
blocked its roads and destroyed hydraulic hoses and three major
pieces of equipment.
Because of Highland’s poor financial condition, the company
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Last modified: May 25, 2011