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Modern,6 but worked at the end of the day at Union Machine to
help Mr. Turner with certain jobs. In mid-1997, petitioner began
working full time at Union Machine because of its increased
workload. Petitioner received an annual salary of $90,000 plus
yearend bonuses. In addition to petitioner and Mr. Turner, Union
Machine employed one full-time employee and some part-time
programmers.
Around 1998, petitioner began experiencing personal
hardships. On one occasion, Union Machine loaned petitioner
$6,000 to pay his tax liability to the IRS. In addition, Mrs.
DeVault filed for divorce after 30 years of marriage to
petitioner. Petitioner needed money to repair his house to sell
in the divorce. Union Machine lent him $16,000 for the repairs.
Petitioner’s personal hardships also began to negatively
affect his work performance at Union Machine, as well as his
business relationship with Mr. Turner. By late 1998, petitioner
left the employment of Union Machine.7 Petitioner stopped
receiving any form of compensation from Union Machine and was no
longer involved with its business-related matters. Around this
6 Petitioner continued to work at Modern because Union
Machine received most of its business from Modern.
7 Petitioner believed that Mr. Turner asked him to leave
because Mr. Turner was concerned that Mrs. DeVault would pursue
an interest in Union Machine. On the other hand, Mr. Turner
believed that petitioner was only taking a temporary leave of
absence. Nevertheless, they agree that petitioner left the
employment of Union Machine in late 1998.
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Last modified: May 25, 2011