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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Last modified: November 10, 2007