Stephen J. Major - Page 4




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          McCulloch.  The supplies were sent to McCulloch’s plant in Mexico           
          where parts were assembled.  The parts were later shipped back to           
          the United States where end products were assembled.                        
          Petitioner’s duties at QSN included overseeing the delivery of              
          QSN’s screws and nuts to McCulloch.  During 1997, petitioner                
          traveled to Mexico approximately once a week.  Petitioner also              
          managed nine Mexican national employees in Mexico.                          
               Petitioner testified that QSN received a 9-percent                     
          management fee based upon the delivery of screws and nuts to                
          McCulloch’s plant in Mexico and the parts shipped back to the               
          United States for assembly.  Petitioner testified that any taxes            
          or fees paid to the Mexican taxing authorities were paid by                 
          petitioner from the 9-percent management fee.  No contracts or              
          agreements between QSN and McCulloch were introduced at trial.              
               During the year in issue, petitioner was a salaried employee           
          of QSN.  In addition to his regular salary, petitioner stipulated           
          that he received a monthly car allowance of $400, totaling $4,800           
          during 1997.  Petitioner also stipulated that he received a                 
          monthly check from QSN of $2,000, totaling $24,000 during 1997.             
          Petitioner does not dispute that he deposited the $400 monthly              
          car allowance and $2,000 monthly check into his personal checking           
          account at DM-Federal Credit Union.                                         
               Both the $400 monthly car allowance and $2,000 monthly check           
          were prepared by Ms. Jacqueline S. Udell (Ms. Udell) at QSN’s               






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