Devine Brothers, Inc. - Page 2




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          references are to the Internal Revenue Code in effect for the               
          year in issue, and all Rule references are to the Tax Court Rules           
          of Practice and Procedure.                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
               Petitioner is a Pennsylvania corporation with its principal            
          place of business in Havertown, Pennsylvania.  Petitioner has               
          been operating as a family-run mechanical contractor business,              
          performing heating, air conditioning, and plumbing services since           
          1918.  The business was started by Michael F. Devine and his                
          brother James Devine.  In the mid-1950s, Michael F. Devine’s son,           
          Richard E. Devine, Sr. (Richard, Sr.), began working for                    
          petitioner.  Petitioner incorporated in 1954.                               
               Richard, Sr. held a bachelor of science degree in                      
          engineering.  Richard, Sr. began working for petitioner when he             
          was about 25 years old.  Richard, Sr. continued the business                
          started by his father and his uncle and by 1961 had acquired                
          100 percent of petitioner’s outstanding common stock.  After                
          becoming the sole shareholder of petitioner, Richard, Sr. had               
          responsibility for human resources, finances, sales and                     
          marketing, training and supervising employees, and accounting and           
          legal matters.                                                              








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