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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference. At the time it filed its petition, petitioner’s
principal place of business was in Sacramento, California.
Petitioner, a corporation, offers architectural services and
other related services to its clients. In its promotional
materials, petitioner describes its services:
Calpo Hom & Dong Architects (CH&D) offers a full range
of architectural services, including master planning,
feasability studies, design, interior design, space
planning, facilities management, construction
administration, historic preservation and consulting
services.
* * * * * * *
Our widely diversified practice, encompassing large
scale planning projects to singular architectural
projects, affords us the latitude of a wide range of
knowledge from which we can draw our thoughts.
Our approach seeks a balanced weighing of elements that
make up architecture: design, the organization of
space and light, structure, systems, and materials.
To carry out these services, petitioner employs licensed
architects, unlicensed architects, and nonarchitects.
1(...continued)
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure. Amounts
are rounded to the nearest dollar.
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Last modified: November 10, 2007