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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact are incorporated herein by this
reference. Leo J. Polack (petitioner) was a resident of
Minnesota when he filed the petition in this case.
Background
Zip Sort, Inc. (ZSI), was incorporated on July 24, 1987, and
petitioner purchased ZSI in August 1987. During 1987, ZSI
employed approximately 10 people and had 30 to 40 regular
customers. ZSI engaged in the trade or business of printing and
preparing pieces of bulk mail for clients and, to that end,
operated lettershop and presorting divisions.
The lettershop division processed mailings for ZSI’s
clients, providing services ranging from printing and folding
materials to stuffing and addressing envelopes. In 1991,
petitioner purchased Stedman Enterprises, an unprofitable
printing company, to bolster ZSI’s lettershop division and as a
backup in the event of an imminent strike.
The presorting division sorted the pieces of bulk mail
according to U.S. Postal Service (Postal Service) criteria in
order to take advantage of Postal Service refund programs.
Initially, ZSI employees manually sorted the pieces of bulk mail,
and the Postal Service discounted the postage for each piece of
mail in each of ZSI’s presorted mailings by 4 cents (presorting
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