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residence, during the years in issue and when the petition was
filed in this case.
Since its organization, petitioner has provided consulting
and surgical services to veterinarians. This activity was and is
petitioner’s only business and only source of income. Sadanaga
has been the sole shareholder of petitioner from the time of its
incorporation and throughout 1997 and 1998.
Sadanaga 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, Sadanaga was elected president, vice president, secretary,
and treasurer. Sadanaga was also petitioner’s sole director.
During 1997 and 1998, Sadanaga performed the following services
for petitioner: (1) Solicited business on behalf of petitioner;
(2) ordered and purchased supplies on behalf of petitioner;
(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) obtained
clients for petitioner; (8) maintained customer satisfaction;
(9) performed all bookkeeping services for petitioner; and
(10) performed all surgical and consulting services to clients on
behalf of petitioner. No other person provided any services to
petitioner.
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