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worked as an electroencephalograph technician at the Rochester
State Hospital in Rochester, Minnesota. She subsequently
obtained a job with International Business Machines in its
manufacturing department, but the record does not indicate how
long she held the job. From 1987 until 1994, Ms. McClelland
taught a part-time physical fitness program at St. John’s
Hospital in Red Wing, Minnesota. However, the majority of Ms.
McClelland’s time was dedicated to managing petitioners’ home,
which included growing and canning produce for the McClelland
family and raising their children.
Red Wing River Towing, Inc.
Red Wing River Towing, Inc. (Red Wing), was a tugboat towing
service corporation. Red Wing elected to be taxed as an S
corporation on November 1, 1995. Red Wing was taxed as an S
corporation for the years in issue, with a fiscal tax year ending
on October 31. The Schedule K-1, Shareholder’s Share of Income,
Credits, Deductions, etc., attached to Red Wing’s Form 1120S,
U.S. Income Tax Return for an S Corporation, for its fiscal tax
year ended October 31, 1997, identified Mr. McClelland as a 50-
percent shareholder and Ms. McClelland as a 50-percent
shareholder. Both Mr. McClelland and Ms. McClelland were
officers of Red Wing during the years in issue. Specifically,
Mr. McClelland was its president, and Ms. McClelland was its
secretary.
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