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under section 61(a), as respondent contends, or a loan excluded
from income, as petitioner contends.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
When the petition in this case was filed, petitioner
maintained its principal office in Stillwater, Minnesota.
Petitioner was incorporated under the laws of the State of
Minnesota on July 13, 1994. During the years at issue, and at
all times subsequent thereto, Richard Zimmerman (Mr. Zimmerman)
and his wife, Janet Zimmerman (Mrs. Zimmerman), each owned 50
percent of petitioner’s issued and outstanding common stock. Mr.
Zimmerman served as president and Mrs. Zimmerman as vice
president. Mr. Zimmerman is primarily responsible for management
of the day-to-day operations of petitioner’s business activities.
Since the date of incorporation, petitioner’s principal business
has been the ownership and operation of two gasoline
stations/convenience stores in Stillwater, Minnesota--one at
14738 North 60th Street (the 60th Street property) and the other
at 2500 West Orleans Street (the Orleans Street property).
1Section references are to the Internal Revenue Code in
effect for the years at issue.
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