James S. & Denise D. Goodfellow, Daniel R. & Claudia Goodfellow, James B. & Nancy B. Goodfellow - Page 16




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          services.  Given that the contracts did not address any sale by             
          GBI of the unusable materials, we conclude that any proceeds                
          which GBI received from such a sale were incidental to the                  
          underlying contracts and merely an economic advantage derived               
          from the contract.  This factor favors respondent.                          
               For the foregoing reasons, we sustain respondent’s                     
          determination.  We have considered all arguments made by the                
          parties and have rejected those arguments not discussed herein as           
          irrelevant or without merit.  Accordingly,                                  

                                                  Decision will be entered            
                                             for respondent.                          




























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