Jose Calvao - Page 2

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          decision are whether petitioner was in the trade or business of             
          gambling during 2002, and whether petitioner is liable for an               
          accuracy-related penalty under section 6662(a).                             
                                  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 he filed his            
          petition, petitioner resided in Tiverton, Rhode Island.                     
               Prior to 1993, petitioner was an operations manager for a              
          textile firm called Prim/Dritz Corporation.  In 1993, petitioner            
          started Caltex Corporation (Caltex), an S corporation.  Caltex is           
          a textile firm which sells embroidered T-shirts, caps, and other            
          similar products.                                                           
               Sometime before 1999, Caltex hired petitioner’s brother with           
          the goal that, once petitioner’s brother learned about the                  
          textile business, petitioner could reduce his involvement in                
          Caltex.  In 1999, petitioner’s brother took over the day-to-day             
          operations of Caltex.                                                       
               During 2002, petitioner was the president and 100-percent              
          owner of Caltex and worked at Caltex 20 to 25 hours per week                
          providing “consulting services”.  In 2002, petitioner received a            
          salary of $42,000 and a distribution of income of $99,790 from              
          Caltex.                                                                     







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