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During the years in issue, petitioner had seven full-time employees (Other Employees), not including the Shareholders, and it paid them on an hourly basis. The

During the years in issue, petitioner had seven full-time employees (Other Employees), not including the Shareholders, and it paid them on an hourly basis. The Other Employees, who were generally neither specialized mechanics nor college educated, were hired and trained by the Shareholders. The Other Employees performed manual labor, such as disassembling the automobiles and sorting the relevant parts, and did not perform management, sales, or executive functions. The Other Employees typically worked a 40-hour week and received overtime for any additional hours. The Other Employees' were paid annual compensation (including bonuses of up to $3,460) ranging from $12,350 to $41,630. The Other Employees were covered by a group medical plan. please summaryze it

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