Sidney C. Shaw - Page 7




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          33.33-percent member and the designated tax matters partner of              
          SDQ LLC during the years in issue.  The day-to-day operations of            
          the Dairy Queen restaurant were managed by Kent Russell                     
          (Russell).                                                                  
               Petitioner renovated the Dairy Queen restaurant in 1995.               
          Petitioner purchased a new cash register system and added a salad           
          display case.  The renovations consisted of relocating the                  
          fountain area to create a separate area for customers to get                
          their drinks, installing new tile, and adding a mop sink closet.            
          The renovation work was done at night so that the restaurant                
          could remain open.                                                          
               During the first 14 weeks of 1995, petitioner was involved             
          in the renovation project and operations of the Dairy Queen                 
          restaurant.  He spent about 7 hours a week at the restaurant                
          busing tables, cooking hamburgers, and fixing the balls in the              
          playroom.  Petitioner met with Russell every morning to review              
          the food and labor costs.  After the first 14 weeks of 1995,                
          petitioner spent about 3 hours a day at the restaurant observing            
          operations.  In 1996, petitioner spent about 3 hours a week at              
          the Dairy Queen restaurant.                                                 
               Petitioner contributed Western Sizzlin’ SW to Shaw Ltd. in             
          May 1995.  In 1996, Shaw Ltd. leased Western Sizzlin’ SW to                 
          Shaw’s Gulf, and Shaw’s Gulf took over the business operations of           








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