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FINDINGS OF FACT
Background
Some of the facts have been stipulated and are so found.1 The
stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference.
Petitioners William and Shirley Pratt are husband and wife.
At the time the petition was filed, petitioners resided in Desert
Hot Springs, California.
William Pratt (petitioner) has a tenth-grade education. After
leaving school, petitioner went to Korea for an unspecified period.
Upon his return from Korea, petitioner became involved in sheet
metal work.
Petitioner owned and operated a sheet metal business under the
name Dormer & Louver of Nevada (Dormer & Louver) in North Las
Vegas, Nevada. Dormer & Louver manufactured gable vents. During
the years at issue, petitioner employed three to five employees,
depending upon the amount of business. Mrs. Pratt worked in the
office of Dormer & Louver when the business first started; she was
a homemaker during the years at issue.
Petitioner turned over all of his business records, including
the checkbook, check stubs, and receipts, for Dormer & Louver to
1 Shirley Pratt neither signed the stipulation of facts nor
appeared at trial. The case with respect to her will be dismissed
for lack of prosecution, and the decision with respect to her will
be consistent with the decision entered with respect to William
Pratt.
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Last modified: May 25, 2011