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located in New Hope, Pennsylvania, at the address of Stark’s
personal residence, when the petition was filed in this case.
Since its organization, petitioner has operated as a
residential home improvement company, providing carpentry, siding
installation, and general residential home improvement and
construction services to the public. This activity was and is
petitioner’s only business and only source of income. Stark has
been the sole shareholder of petitioner from the time of its
incorporation and throughout 1996, 1997, and 1998.
Stark has at all times served as petitioner’s president and
only officer. Minutes from petitioner’s annual meetings of
directors and shareholders reflect that, for each of the years in
issue, Stark was elected president, vice president, secretary,
and treasurer. Stark was also petitioner’s sole director.
During 1996, 1997, and 1998, Stark performed the following
services for petitioner: (1) Solicited business on behalf of
petitioner; (2) ordered petitioner’s supplies; (3) entered into
verbal and/or written agreements on behalf of petitioner;
(4) oversaw the finances of petitioner; (5) collected moneys owed
petitioner; (6) managed petitioner; (7) supervised work performed
on behalf of petitioner; (8) acquired customers for petitioner;
(9) performed all bookkeeping services for petitioner; and
(10) made all hiring decisions and paid all individuals who
performed services in connection with petitioner’s residential
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