Wagner Construction, Inc. - Page 23




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               (a)  Petitioner won and held onto logging contracts with               
          Boise Cascade Corp.;                                                        
               (b)  petitioner purchased land (or rented land from Wagner &           
          Wagner) to store construction wastes from its construction                  
          operations and for others;                                                  
               (c)  petitioner converted portions of land from construction           
          waste storage to log storage for its logging operations and those           
          of Boise Cascade Corp.;                                                     
               (d)  petitioner purchased land and developed sand and gravel           
          pits for use in its construction business and for sale to others;           
               (e)  petitioner entered into advantageous agreements to                
          extract gravel from other properties for use in its construction            
          business and its sand and gravel operations;                                
               (f)  petitioner's revenues increased from $2.1 million in              
          1986 to $6.1 million in 1996;                                               
               (g)  from 1985 to 1996, both Dennis and Curtis devoted                 
          themselves exclusively to petitioner's construction and related             
          businesses, and they worked up to 90 hours per week;                        
               (h)  by 1995, Dennis had more than 30 years of experience              
          and Curtis had more than 20 years of experience in the                      
          construction and logging industries; and                                    
               (i)  Dennis and Curtis were petitioner's only officers from            
          1985 to 1996; they performed all the executive and administrative           








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