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Haff began working for petitioner part time in 1951. During
the subject years, he was its general manager, working
approximately 13 hours a day. In that capacity, he set the price
at which petitioner would sell its gasoline and home heating oil
to its customers and made most of petitioner’s other business
decisions. Haff received from petitioner compensation of
approximately $742,400, $592,000, and $469,250 in the respective
subject years. Part of each year’s compensation was apportioned
to at least HCC and Parker, and petitioner claimed a deduction
for the rest.
During the subject years, Emile opened petitioner’s office
each morning sometime between 4:30 a.m. and 5 a.m. He also made
bank deposits for some of the stations, collected items from all
of the stations, and discussed many of the business decisions
with Haff before Haff decided upon and implemented them. Emile
also helped answer the telephones and discussed home heating oil
matters by telephone with various individuals. Emile received
from petitioner a weekly salary of $425. Part of the salary was
apportioned to at least HCC and Parker, and petitioner claimed a
deduction for the rest.
During the subject years, Louise helped answer the
telephones, took customer orders, drafted and signed checks, made
bank deposits, conversed with customers and employees, and
performed minor tasks around the office. She also communicated
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