James M. and Karen K. Barton - Page 2

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               Unless otherwise indicated all section references are to the           
          Internal Revenue Code in effect for the year at issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, accompanying exhibits, and stipulation            
          of settled issues are incorporated by this reference.                       
          Petitioners resided in Houston, Texas, at the time they filed the           
          petition.                                                                   
               Petitioner was employed by Armko Industries, Inc. (Armko), a           
          roof system consulting firm, as a sales representative during               
          2000.  Petitioner was responsible for consulting with clients,              
          predominantly school districts, regarding their roofing needs and           
          assisting them in overseeing the planning and implementation of             
          roofing projects.  This included identifying the condition of the           
          current roof, developing specifications for the project, meeting            
          with local construction contractors who bid on the project, and             
          attending preconstruction meetings with the school district and             
          the contractors.  Once construction began, petitioner documented            
          the progress and authorized payments to the contractors.  When              
          the project was completed, petitioner prepared a list of items              
          that had to be remedied before the contractor would be paid and a           







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