Timothy Dean Strong - Page 4

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time of filing his           
          petition in this case, Mr. Strong resided in Clear Lake,                    
          Minnesota.  At the time of filing its petition, SCC had its                 
          principal place of business, mailing address, and registered                
          office in Minnesota.                                                        
          SCC                                                                         
               SCC was incorporated under Minnesota law in 1986, and as of            
          December 31, 1994, had not been formally dissolved.  At all times           
          relevant, Mr. Strong was the 100-percent owner of SCC.  He was              
          its incorporator, director, and president.  During the years at             
          issue, SCC had no officers except Mr. Strong and had no                     
          employees.                                                                  
               During the years at issue, SCC was engaged in the                      
          residential construction business and built and sold houses under           
          the names Strong Construction or Strong Construction Co., Inc.              
          SCC constructed and sold the following houses (the 22 house                 
          sales):                                                                     












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