- 4 - 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).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