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FINDINGS OF FACT4
Some facts have been stipulated and are so found. The
stipulation of facts, with attached exhibits, is incorporated by
this reference.
At the time the petitions were filed, petitioner Sid Paul
Ruckriegel (Sid) resided in Peoria, Illinois, and petitioner Al
A. Ruckriegel (Al) resided in Terre Haute, Indiana.
Sidal, Inc.
Sidal, an Indiana corporation, elected S corporation status
at the time of its organization in 1993 and retained that status
through December 31, 2000. During that period, petitioners were
each 50-percent shareholders in Sidal. Sidal operated
approximately 50 fast food franchise restaurants throughout
Indiana and part of Illinois during the 1997-2000 period. From
its incorporation in 1993 through 2000, Sidal operated at a loss.
Sid and Al actively managed the Sidal restaurants.
Paulan Properties Partnership
From its formation, in 1993, through December 31, 2000,
petitioners were each 50-percent partners of Paulan Properties
Partnership (Paulan), a general partnership governed by Indiana
4 To the extent that petitioners fail to object to
respondent’s proposed findings of fact, or vice versa, we
conclude that those proposed findings of fact are correct except
to the extent that the nonobjecting party’s proposed findings of
fact are clearly inconsistent therewith. See Jonson v.
Commissioner, 118 T.C. 106, 108 n.4 (2002), affd. 353 F.3d 1181
(10th Cir. 2003).
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