- 3 - During the years in issue, Dennis and Curtis were petitioner's sole stockholders. Dennis and Curtis are the sons of Clifford Wagner (Clifford) and Evelyn Wagner (Evelyn). Dennis was born in 1952, and graduated from high school in 1971. Curtis was born in 1954, and graduated from high school in 1973. Neither Dennis nor Curtis attended college. Both began working with their father when they were young boys. Petitioner is the successor to a partnership called Clifford Wagner & Dennis Wagner Construction (Wagner & Wagner). Clifford and Dennis formed Wagner & Wagner in 1974 to conduct a logging business. In 1976, Wagner & Wagner acquired a construction business that previously had been owned by Clifford and a third individual. Clifford and Dennis each owned a 50-percent interest in Wagner & Wagner. On November 1, 1985, Clifford and Dennis incorporated petitioner. At that time, the construction business of Wagner & Wagner was well established; the partnership had approximately 30 employees1 and normally operated four construction crews during the construction season. Wagner & Wagner transferred assets of $638,916 and liabilities of $127,543 to petitioner. The transfer was treated as a contribution to capital on petitioner's books. The amount 1Wagner & Wagner had seven or eight full-time employees; the other employees were seasonal.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011