- 3 -
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. Petitioner resided in
Phoenix, Arizona, at the time he filed his petition in this case.
Petitioner’s Background
Petitioner graduated from high school in 1972 and
immediately thereafter began working in the air-conditioning
business by installing ductwork for his father. In 1976, after
attending one semester of college, petitioner went to work for
Geottle’s Metal Products (Geottle). Petitioner’s initial
responsibilities at Geottle included installing sheet metal and
air-conditioning units. He later worked his way up into the
estimating department, where he bid jobs on behalf of his
employer.
In 1985, petitioner left Geottle and formed his own business
called the A/C Co. (the company).2 The company specialized in
the installation of air-conditioning equipment and associated
ductwork, and the company’s principal place of business was
located in Mesa, Arizona. The activities of the company during
1992 constitute the focus of respondent’s determination.
2 The company was initially operated as a partnership
between petitioner and an associate, whom petitioner later bought
out. At all times during the 1992 tax year, the company was
operated by petitioner as a sole proprietorship.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011