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Petitioner’s business primarily sells to the Federal
Government office supplies consisting of staplers, staple
removers, and letter openers. As to its sales, petitioner
usually causes the subject merchandise to be delivered to the
customer directly from its suppliers, mainly Panasonic.
Sometimes, usually in the case of small orders, petitioner ships
the merchandise directly to the customer from petitioner’s
inventory. Petitioner does not sell at retail.
Petitioner’s business requires minimal labor. Ms. Odell
primarily handles the business’s day-to-day administration; e.g.,
dealing with and paying suppliers, talking with customers by
telephone, processing customer orders, and bookkeeping. But for
a limited amount of outside laborers, who during the relevant
years received minimal pay, the only other individual who works
for petitioner is Mr. Odell. Mr. Odell works for petitioner’s
business approximately the same amount of time as Ms. Odell,
doing, among other things, all of the shipping and computer work
and helping facilitate sales. Unlike Ms. Odell, who is paid for
her time, Mr. Odell receives no pay from petitioner. Mr. Odell’s
primarily source of income is his employment as a locomotive
engineer with Union Pacific Railroad. There he works 4
consecutive days and then has the next 4 days off.
During petitioner’s typical business day, petitioner
(through Mr. or Ms. Odell) checks the fax machine for incoming
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Last modified: May 25, 2011