Brewer Quality Homes, Inc. - Page 4

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               Petitioner is engaged in the business of retail selling of             
          manufactured homes, also known as mobile homes, trailers, or                
          trailer homes, hereinafter sometimes collectively referred to as            
          mobile homes.  At all relevant times, Jack and Mary each owned 50           
          percent of petitioner’s stock.  Petitioner’s stock was not                  
          publicly traded.                                                            
          A.  Jack’s Background                                                       
               Jack served in the U.S. Marine Corps for 3 years.  In 1954,            
          he left the Marine Corps and moved to Dallas, Texas, where he               
          began a career in the automobile business.  Jack served as the              
          sales, finance, and insurance manager for several General Motors            
          dealerships.  In 1973, he left the automobile business to pursue            
          a career in the mobile home business.                                       
          B.  Petitioner’s Origin and Economic Development                            
               Jack began his mobile home retailing business with capital             
          raised from the $8,000 of equity that he had in his home and a              
          $50,000 bank loan.  He used this capital to establish an                    
          inventory of about six mobile homes.  Jack increased his                    
          inventory by buying distressed merchandise at a discount--new               
          mobile homes that lenders had repurchased from retailers who were           
          going out of business.  He attributed the failures of other                 
          retailers’ businesses to an economic downturn that began in 1973.           
               Jack did not employ anyone in his mobile home retailing                
          business during its first year.                                             






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Last modified: May 25, 2011