- 3 -
operated as an S corporation. Petitioner’s principal place of
business has been located in Levittown, Pennsylvania, at the
address of Ludlow’s personal residence, from the time of its
incorporation to the present.
Since its organization, petitioner has provided pickup and
delivery services to distributors, wholesalers, and manufacturers
of steel, steel coil, and steel-related products. This activity
was and is petitioner’s only business and only source of income.
Ludlow has been the sole shareholder of petitioner from the time
of its incorporation and throughout 1996, 1997, and 1998.
Ludlow 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, Ludlow was elected president, vice president, secretary,
and treasurer. Ludlow was also petitioner’s sole director.
During 1996, 1997, and 1998, Ludlow performed the following
services for petitioner: (1) Ordered and purchased supplies on
behalf of petitioner; (2) entered into verbal and/or written
agreements on behalf of petitioner; (3) oversaw the finances of
petitioner; (4) collected moneys owed petitioner; (5) managed
petitioner; (6) maintained customer satisfaction; (7) performed
all bookkeeping services for petitioner, with assistance from his
spouse, Sharon Ludlow, from time to time; and (8) performed all
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011