- 3 -
FINDINGS OF FACT
Some of the facts are stipulated. The stipulation of facts,
the supplemental stipulation of facts, and the attached exhibits
are incorporated herein by this reference. At the time the
petition was filed, petitioners resided in Minneapolis,
Minnesota.
Petitioners operated HRDC as a partnership in 1993 and 1994,
and as a corporation subject to the provisions of subchapter S in
1995. HRDC was in the business of roof repair for commercial
properties. HRDC was owned during the years in issue as follows:
1993 1994 1995
Wayne Payne (Mr. Payne) 50% 50.0658% 100%
Mrs. Payne 50 49.9342 0
HRDC operated from offices in a building owned by
petitioners. During the years in issue, Mr. Payne was
responsible for HRDC’s roofing work, and Mrs. Payne worked in
HRDC’s offices. Mrs. Payne and Cari Enerson (Ms. Enerson)
maintained HRDC’s books and records. Ms. Enerson was hired by
HRDC as its bookkeeper after her graduation from high school.
Before beginning her employment with HRDC, Ms. Enerson’s work
experience consisted of waitressing.
Before HRDC received a roofing job, Mr. Payne or one of
three employees of HRDC visited a potential customer’s site and
prepared a bid for roof repair work. The bid was then sent to
the potential customer. If the customer accepted the bid, he
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011