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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
1. Domer Ishler
Petitioner lived in Huntsville, Alabama, when he filed his
petition in this case. He graduated from high school and
completed 6 months of trade school in electronics.
Lela Ishler is petitioner's mother, and her husband is D.
Marvin Ishler. Marvin M. Ishler is petitioner's brother. Traci
Ishler is petitioner's daughter. Joyce Ishler Eller (Eller) is
petitioner's former wife. Melonee Hudson (Hudson) was
petitioner's niece. She died in July 1994.
During the 1980s, petitioner conducted business and
investment activities through a sole proprietorship named Double
D Investments. Petitioner maintained a checking account at
Central Bank in Huntsville for Double D (the Double D account).
2. 20th Century Marketing, Inc.
TCM’s principal office was in Huntsville when it filed its
petition in this case. Petitioner incorporated TCM in 1967 and
was its only employee until 1970. TCM was a C corporation for
1987 and an S corporation for 1988. Petitioner was TCM’s sole
shareholder and chief executive officer in 1987 and 1988. TCM
had 34 employees and annual sales of about $90 million by 1989.
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