Robert L. and Brenda J. Tarter - Page 4




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          equipment assets that petitioner used for the concrete                      
          construction business were transferred to V&E Leasing during                
          2001.  No Form 1065 was filed for V&E Leasing for 2001.                     
               Also on September 15, 2000, petitioner set up the entity               
          B & B Concrete Pumping, Ltd., a California limited partnership              
          (B&B Concrete Pumping).  The partners of B&B Concrete Pumping               
          were petitioner and Granite Bay Complex Trust.  Upon formation of           
          B&B Concrete Pumping, petitioner held a 1-percent interest and              
          Granite Bay Complex Estate Trust held a 99-percent interest in              
          B&B Concrete Pumping.  The bigger, more expensive concrete pumps            
          that petitioner used for the concrete construction business were            
          transferred to B&B Concrete Pumping during 2001.  No Form 1065              
          was filed for B&B Concrete Pumping for 2001.                                
          C.   Payments to Workers                                                    
               Beginning in October 2000, petitioner began to use a payroll           
          system under which B&B’s approximately 100 to 200 employees were            
          leased to an employee leasing company, Labor Force Partners, Ltd.           
          (payroll company).  Through this leasing arrangement, the payroll           
          company became the primary legal employer of record.                        
               The individuals who originally presented and promoted                  
          the payroll system to petitioner were David Clancy and Ray                  
          Vallejo.  In September 2000, petitioner arranged for an                     
          all-employee meeting for B&B workers.  At that meeting, Clancy              
          and Vallejo told the employees about the new payroll system.                







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