- 3 - petitioner’s stock.2 On June 30, 1982, Dean paid $2,150 to petitioner for 43 additional shares of its stock, and Darle’s other brother Rocky Miller (Rocky) paid $4,650 to petitioner for 93 shares of stock. From June 30, 1982, until June 30, 2000, petitioner was owned by the three brothers as follows: Shareholder Percent Ownership Darle Miller 51.8% Dean Miller 24.1 Rocky Miller 24.1 Since its inception, petitioner’s tax year has ended June 30. B. Petitioner’s Business Petitioner’s primary business was interior wall construction. Wall construction includes the placing of studs, insulating the walls, hanging drywall and other wall materials as required, and drywall taping (collectively, the drywall construction business). Since the early 1990s, petitioner has limited its geographic business area to Fargo, North Dakota, and Moorhead, Minnesota. Petitioner was a subcontractor. It was awarded construction jobs from general contractors by submitting the lowest bid to complete a specific job (a lowest bid commodity business). Petitioner primarily bid on commercial construction projects. After being awarded a job, petitioner purchased the supplies 2The record is devoid of an explanation why Darle paid less than Dean for each share of petitioner’s stock.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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