- 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