WSB Liquidating Corporation - Page 3

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          (2) Whether petitioner is liable for accuracy-related penalties             
          as determined by respondent.  We hold that petitioner is liable.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  We           
          incorporate by this reference the stipulation of facts and the              
          attached exhibits.  At the time of filing the petition,                     
          petitioner had been dissolved.  Petitioner’s principal place of             
          business had been Wilmington, Delaware.                                     
               Barbara and Walter Bandurski (Walter) founded and                      
          incorporated petitioner in 1967.  Petitioner was engaged in the             
          trash removal business.  Petitioner was a close corporation under           
          Delaware law and was managed directly by its stockholders.1                 
               Walter and Barbara were married in 1956.  They both worked             
          for petitioner.  From 1967 until 1983 or 1984, Barbara                      
          essentially ran the office; she worked full time for petitioner             
          as office manager, bookkeeper, and corporate secretary.  Barbara            
          had a good rapport with customers; in general customers preferred           
          dealing with her rather than Walter.                                        
               Walter and Barbara were divorced in August of 1984.                    
          Beginning in 1983 or 1984, Barbara’s work for petitioner was less           
          than full time; generally she appeared for work fewer than 5 days           
          per week.  Also in 1984, an unrelated employee replaced Barbara             

               1 However, petitioner was not an S corporation as defined in           
          sec. 1361(a).                                                               

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