TRB-88-038-AK, 6-3001-2075-2

                                                   CHTR 32193, 59548/T-87-468

                                                   CSC 9115, 59548/T-87-470

                                                   LCC 596, 914/T-87-467

                                                   IRCC 32193, 59548/T-87-469

 

 

                               STATE OF MINNESOTA

                       OFFICE OF  ADMINISTRATIVE  HEARINGS

 

               FOR THE MINNESOTA TRANSPORTATION REGULATION BOARD

 

 

In the Matter of the                                      FINDINGS OF FACT,

Consolidated Hearings                                     CONCLUSIONS,

Related to Space Center                                   RECOMMENDATIONS

Transport and Wintz                                       AND MEMORANDUM

Freight Systems

 

 

    The above-entitled matter came on for  hearing  before  Allan W. Klein,

Administrative Law Judge, on May 2 and 3, 1988,  in  South  St. Paul.

 

    Appearing on behalf of the Transferor,  Space  Center,  Inc., was William B.

Hockensmith, General Counsel, Space Center, Inc., 444 Pine Street, St. Paul,

Minnesota 55101.

 

    Appearing on behalf of the Transferee, DGT Properties, Inc. was Corey J.

Ayling, of the firm of O'Connor & Hannan, 3800 IDS Center, Minneapolis,

Minnesota 55402.

 

    Appearing on behalf of Protestant Bjorklund Trucking was Andrew R. Clark,

of the firm of Mackall, Crounse & Moore, 1600 TCF Tower, 121 South Eighth

Street, Minneapolis, Minnesota 55402.

 

    Appearing on behalf of Intervenor Commissioner of Transportation was

Special Assistant Attorney General John B. Galus, 515 Transportation Building,

St. Paul, Minnesota 55155.

 

    The record closed on August 1, 1988.

 

    Notice is hereby given that, pursuant to Minn.  Stat.  14.61, and the

Rules of Practice of the Public Utilities Commission, as applicable to the

Transportation Regulation Board, and the Rules of the Office of Administrative

Hearings, exceptions to this Report, if any, by any party adversely affected

must be filed within 20 days of the mailing date hereof with the Transportation

Regulation Board, Minnesota Administrative Truck Center, 254 Livestock Exchange

Building, 100 Stockyards Road, South St. Paul, Minnesota 55075.   Exceptions

must be specific and stated and numbered separately.  Proposed Findings of

Fact, Conclusions and Order should be included, and copies thereof shall be

served upon all parties.  If desired, a reply to exceptions may be filed and

served within ten days after the service of the exceptions to which reply is

made.  Oral argument before a majority of the Board may be permitted to all

parties adversely affected by the Administrative Law Judge's recommendation

who request such argument.  Such request must accompany the filed exceptions

 


or reply, and an original and five copies of each  document  must  be  filed  with

the  Board.

 

    The Minnesota Transportation Regulation Board will make the final

determination of the matter after the expiration of the period for filing

exceptions as set forth above, or after oral  argument,  if  such  is  requested

and had in the matter.

 

    Further notice is hereby given that the Board  may,  at  its  own  discretion,

accept or reject the Administrative Law Judge's recommendation and that said

recommendation has no legal effect unless expressly  adopted  by  the  Board  as

its final order.

 

                               STATEMENT OF ISSUES

 

    May the IRCC and LCC permits presently held by subsidiaries of Space

Center, Inc. be transferred to subsidiaries  of  DGT  Properties,  Inc.  without

violating the provisions of Minn.  Stat.  221.151?  More particularly, who

effectively controls DGT Properties, Inc.  -- George W. Wintz, Jr. or Thomas G.

Wintz?

 

    Based upon all of the proceedings herein, the Administrative Law Judge

makes the following:

 

                                 FINDINGS OF FACT

 

 

Historical_Baclground

 

    1.    Prior to the summer of 1987, Space Center,  Inc.  owned  and  operated

Space Center Transport, Inc.  This was an intrastate carrier holding LCC and

IRCC permits.  It also owned a charter permit which  is  not  at  issue  in  this

proceeding.

 

    2.    Prior to the summer of 1987, Space Center, Inc. also owned and

operated Sterling Cartage Company, which held a courier services carrier

permit, which is no longer at issue in this proceeding.

 

    3.    In the two-year period prior to June of 1987, Space Center Transport,

Inc. used its LCC authority to handle  general  commodities  throughout  the  Twin

Cities commercial zone.  Accounts included 3M Company and Ford.  T. 40-41.

 

    4.    In the two-year period prior to June of 1987, Space Center Transport,

Inc. used its IRCC authority to transport general commodities for a large

number of customers.  An abstract of activity during 11 months (Ex. 102)

demonstrates service to approximately 100 Minnesota cities involving a broad

array of general commodities.  T. 46-49, Ex. 103 and 104.

 

    5.    In the fall of 1986, Space Center, Inc. decided to explore the

divestiture of Space Center Transport and  Sterling  Cartage  either  through  a

sale of the assets, sale of the  stock,  or  through  liquidations.  It  attempted

to locate a buyer for the companies,  and  ultimately  began  negotiations  with

George W. Wintz, Jr. in the spring of 1987.  T. 9.

 

    6.    After negotiations in May and June of 1987, it  was  agreed  that  the

transportation businesses of Space Center, Inc. would be sold to DGT

 

 

                                       -2-

 


Properties, Inc.  One of the conditions of the  sale  was  that  the  Space  Center

name and logo could not be used after the sale.  Immediately prior to the

sale, Space Center Transport changed its  name  to  Wintz  Freight  Systems,  Inc.

The sale took the form of a sale of stock, so that  what  was  actually  sold  was

100 percent of the stock of Wintz Freight Systems,  Inc.  by  Space  Center,  Inc.

to DGT Properties, Inc.  After the sale, which occurred on June 19, 1987,

Space Center, Inc. took no part in the operation of the transportation

businesses.

 

    7.   DGT Properties, Inc. is a Minnesota corporation.  It was formed on

May 19, 1986.  The sole shareholder was  George  Wintz.  Its  first  officers  were

George Wintz, President; Thomas Wintz, Vice-President; and Julie McDonald,

Secretary.  The sole director was George Wintz.

 

    B.   George Wintz is a successful trucking entrepreneur who owns Wintz

Truck Leasing Co., Winko Warehouse, Milbank  Freightways,  Quality  Drivers,  Twin

City Garage & Trailer Repair,  and  Opportunity  Management,  Inc.  He  also  owns

98 percent of a partnership  known  as  Wintz  Investment  Company.  George  Wintz

has a personal net worth in excess of $10 million.  T. 229.

 

    9.   Wintz Truck Leasing holds local cartage,  charter  and  contract  carrier

authority pursuant to Minn.  Stat. ch. 221.  Winko  Warehouse  also  holds  a  local

cartage permit.  Milbank Freightways operates as an interstate carrier.

Opportunity Management, Inc. provides legal,  financial  and  accounting  services

to George Wintz and his various companies and to  Thomas  Wintz  and  his  various

companies.

 

    10.  George Wintz was born in March of 1940.  He began working in the

trucking business when he was still in school as a driver, and, in 1965,

started his own company.  He has  been  involved  in  the  transportation  industry

since then.  He has two children, Thomas George Wintz and Debra Strom.

 

    11.  Thomas Wintz was born in April of 1966.  He is currently 22 years

old.  He graduated from St. Thomas College in June of 1988.  He was,

therefore, still a student at the time of the hearing and at all times

discussed in this Report.  He is legally blind, but has progressed through

high school and college with a high degree  of  success.  He  graduated  from  St.

Thomas cum laude, with a 3.51 (A-) grade point average overall, and a 3.70

(A-) grade point average in his major field.  T. 266.  He has developed an

interest in electronics, having been licensed as  an  amateur  radio  operator  as

a child, and has since become involved with computers.  He  has  an  aptitude  for

independent study and self teaching, and has  developed  an  ability  to  program,

debug and operate both microcomputers and minicomputers.  T. 268.

 

    12.  Since the start of high school, and extending intermittently during

his college career, Thomas Wintz has performed various  duties  for  his  father's

businesses.  He has done  computer  consulting,  programming  and  debugging  since

the ninth grade.  In addition, he has been a dock laborer, dock foreman, and

weekend dispatcher.  T. 258-78.

 

    13. For a number of years, it has been the  goal  of  both  George  Wintz  and

Thomas Wintz that Thomas would establish himself in  the  trucking  industry,  but

independent of his father.  T. 64, 280.  A logical time for him to do this

would be upon his graduation from college.  His college graduation was

scheduled for June of 1988.  The acquisition of the Space Center businesses

occurred in June of 1987, a year ahead of the graduation date.

 

 

                                      -3-

 


The First Year of DGT and the Acquisition of the_Space Center Businesses

 

    14. DGT was formed in May of 1986.  At the outset,  George  Wintz  was  its

sole director, sole shareholder and president.  T. 58, Ex. 114.

 

    15.  DGT Properties was named for George Wintz and his children, the

initials being the first letters of their first names, Debbie,  George  and

Tom.  T. 391.  George Wintz's testimony that there was no particular

significance to the initials is not credible.  T. 58, 105.

 

    16. In the spring of 1986, George Wintz entered into  an  agreement  whereby

Wintz Investment Company would purchase a truck terminal located at 2707

Territorial Road in St. Paul.  The purchase price  was  $500,000.  T.  117.  Once

DGT was formed, George Wintz assigned Wintz Investment's rights  under  the

purchase agreement to DGT.  DGT then purchased the terminal.  T. 118.

 

    17. DGT financed the purchase of the terminal with a  $650,000  loan  from

Sprague National Bank.  This bank loan was guaranteed by George Wintz

personally.  Financing of the Territorial Road terminal resulted in a

$299,579.87 balance which was deposited in DGT's checking account at  the  St.

Anthony Park Bank.  Ex. 7 and 8. The sole signatory  on  that  checking  account

at the St. Anthony Park Bank was George Wintz.

 

    18. For approximately the next six months DGT leased  the  Territorial  Road

terminal to Mix Transfer.  T. 61.

 

    19. In October of 1986, George Wintz caused DGT to  acquire  two  residen-

tial condominiums, one in Roseville and the other in  Scottsdale,  Arizona.

These condominiums had originally been acquired by George Wintz,  who  assigned

them to Tom Wintz, who, in turn, assigned them to DGT Properties.  The

condominiums still carried a mortgage from Sprague National Bank, which was

also assigned to DGT.  T. 106-08.  Since October of 1986, and for some time

before then, George Wintz has occupied the Roseville condominium  rent-free  as

his principal residence.  The Arizona condominium has been  used  by  George

Wintz, Thomas Wintz and other family members as a vacation  property.  T.  108.

DGT makes all mortgage payments on both condominiums.  In  addition,  DGT  pays

the association fees charged for the Arizona condominium.  George  Wintz  pays

the association fees for the Roseville condominium.  T. 108-09.

 

    20.  In addition to paying the association fees for the Arizona condo-

minium, DGT also pays the association fees for a second  Arizona  condominium,

which is owned by Thomas Wintz, but is occupied by his grandmother and

grandfather.  T. 234-35.

 

    21.  During the first year of DGT's operations, the balance in its St.

Anthony Park Bank checking account declined from its high of $299,579.87 on

May 30, 1986 to $2,843.17 on May 29 of 1987.  The bulk of the money was

withdrawn during June and July of 1986, and for the most part  the  balance

remained under $5,000 since the end of July, 1986.  This reduction was

accomplished by George Wintz writing out checks totalling $181,700  to  himself,

$169,000 to Wintz Investment Company, and $50,000 to obtain an option on a

terminal which was later assigned to Wintz Truck Leasing.  The  total  of  such

intercompany transfers out of DGT during that year was,  therefore,  $400,700.

 

 

                                      -4-

 


    22.  During the first year of operations, money deposited into the DGT

checking account from George Wintz and his companies totaled  $190,885.93.  Of

this, $170,852.35 came from George Wintz personally, $18,008.51 came from

Wintz Investment Company, and $2,025.07 came from Opportunity Management

Services.

 

    23.  Although both George and Thomas Wintz testified that it was the

intent of both that various intercompany transfers between DGT and George

Wintz (and his companies) would be interest bearing in both directions,  there

is no evidence that any interest has, in fact, been computed or paid,  either

by DGT or by George Wintz and his companies.  While DGT has made regular

payments to banks and others outside of the family operations, there have  not

been regular payments made to or from the family operations to reflect any

regular settling of debts or payment of interest for the May '86-May '87  time

period.

 

    24. Explanations for the intercompany transactions included  an  argument

that it made no sense to leave large sums of money sitting in the DGT  checking

account because that account was non-interest bearing, and, that advances  made

to George Wintz or his companies enabled them to make profitable  investments

that would eventually be credited to the benefit of DGT.  However, there  is  no

paperwork memorializing these "investments", so that it would be impossible

based on this record to determine what profits were due to DGT or, for that

matter, if there were any profits at all.  George Wintz candidly  explained  why

he wrote some checks to himself individually, while he wrote others to  Wintz

Investment Company -- it depended upon which entity needed the money at  that

particular time.  T. 80-81.  Moreover, George Wintz was unable to recall or

identify the details of any of the investments which were allegedly made  for

the account of DGT.  T. 178-80.

 

 

Purchase of the Space_Center Businesses

 

    25.  As detailed earlier, George Wintz negotiated, on behalf of DGT

Properties, for the purchase of 100 percent of the common stock of two

subsidiaries of Space Center Transport, Inc.  By the time of the purchase,

these had been renamed Wintz Freight Systems, Inc. and Sterling Freight

Systems, Inc.  The negotiations were handled entirely by George Wintz, and

Thomas Wintz did not participate in them at all.

 

    26.  In payment for the stock of these businesses, DGT paid $370,000 in

cash, and transferred the Territorial Road terminal free and clear of any

outstanding obligations.  The total transaction was valued at approximately

$1,020,000.

 

    27.  In order to come up with the $370,000 cash portion of the payment,

George Wintz arranged for DGT to borrow $370,000 from the Maplewood State

Bank.  The loan was personally guaranteed by George Wintz, and further secured

by his pledging the equipment of Wintz Truck Leasing as collateral.  T. 67,

73-74, and 184-89.

 

    28.  In order to transfer the Territorial Road terminal free and clear, it

was necessary to pay off the existing mortgage.  In order to do  this,  George

Wintz caused Wintz Truck Leasing to loan $1.4 million to DGT.  On July 2,  1987,

 

 

                                     -5-

 


George Wintz signed a note on behalf of DGT for the $1.4  million.  Ex.  110.

Part of the proceeds of this loan was used to clear the mortgage,  and  the

remainder ($712,552.20) was deposited in DGT's checking account.  T  221,  380

and Ex. 22.  The purpose of the excess cash was to provide sufficient operating

funds for DGT.  Operating funds were needed because DGT had taken  on  the  Space

Center businesses, and Space Center's pro forma combined balance  sheets  for

Wintz Freight Systems and Sterling indicated that current  liabilities  exceeded

current assets by $664,000.

 

 

Scaling Down the Space Center Businesses

 

    29. At the time of the June 19, 1987 stock sale from Space  Center  to  DGT,

Space Center Transport and Sterling Cartage, together,  enjoyed  approximately

$6,000,000 in annual traffic.  Sterling owned approximately 50 units of

rolling stock, and Space Center Transport owned between 50 and  75  motorized

units and approximately 250 trailers.  T. 189-94,  199-200,  and  328-34.  Thomas

Wintz felt this was more than he could handle.  T. 280-81.

 

    30. Wintz Truck Leasing and DGT agreed that within six months  of  July  2,

1987, DGT would sell certain rolling stock to Wintz Truck Leasing for  a  price

to be negotiated, but not to exceed $800,000.  This was one  of  the  provisions

in the $1.4 million loan agreement.  This sale did, in  fact,  occur  shortly

after the June 19 stock transfer.  The fair market value of  the  rolling  stock

was approximately $1.0 million.  Its book value was  around  $700,000.  T.  319.

 

    31.  The $1.4 million note from DGT to Wintz Truck Leasing calls for

interest to be paid monthly, commencing February 2, 1988, up to  and  including

January 2, 1991, at which time the entire balance then remaining is  due  and

payable.  By the date of the hearing (May 1988), DGT had  made  no  interest

payments to Wintz Truck Leasing.  T. 350.  Depending  upon  how  the  rolling

stock is valued (its fair market value was $1.0 million, but the note  SayS  the

purchase price shall not exceed $800,000), the balance outstanding on  the  note

is either $400,000 or $600,000.  Interest is at the rate of  nine  percent,  and,

therefore, the monthly interest payments would be somewhere between  $3,000  and

$4,500.  But if the various monies transferred in and out of  DGT  by  George

Wintz and his companies are deemed to affect the outstanding balance  on  this

note, then the amount of interest due and owing, if any, is unknown,  as  there

has been no final accounting of those various transfers.  T. 351.

 

    32. The sale of the rolling stock resulted in all  of  Sterling's  rolling

stock going to Wintz Truck Leasing, and all but between 20 and 25  of  Space

Center Transport's tractors going to Wintz Truck Leasing.  Aside  from  new

equipment purchased since then, the balance of the Space  Center  equipment  is

currently owned and operated by Wintz Freight Systems.

 

    33. In addition to the rolling stock, some of the  business  that  used  to

be carried by the Space Center companies has gone to Wintz  Truck  Leasing.

Wintz Truck Leasing acquired approximately $3.0 million of  annual  traffic

previously serviced by the two Space Center businesses, and  Wintz  Freight

Systems retained approximately $1.4 million.  Sterling Cartage  is  dormant,  and

handles no traffic.  The balance of the Space Center business  is  being  handled

by other carriers.

 

 

 

 

                                     -6-

 


Sale of DGT From George_to Thomas Wintz

 

    34. The sale of DGT stock from George Wintz to Thomas  Wintz  was

accomplished sometime in May of 1987.  The records are contradictory with

regard to the exact date.  The actual purchase agreement for the sale  of  the

stock is dated May 27, 1987, and calls for a closing on May 27.  The  payment

for the stock was a $40,000 note.  That note is dated May 12, 1987,  and  refers

to a purchase agreement dated May 12.  There is no purchase  agreement  dated

May 12 in the record.  Ex. 107 and 108.  The corporate  records  indicate  that

the stock certificate owned by George Wintz was surrendered on May 27,  and

formally received on May 29, but a new stock certificate to Thomas Wintz  was

not issued until July 25.  Ex. 114, T. 286.  Neither George  nor  Thomas  Wintz

have any independent recollection of the dates upon which these various

documents were executed, and it can only be concluded that either the  stock

purchase agreement or the note is in error.  T. 205-06, 382-84.

 

    35. June 19, 1987 was the closing date for the sale of the stock  of  the

Space Center businesses to DGT.  George Wintz attended the closing,  which  was

a complex and prolonged affair, lasting over 15 hours.  Near the end  of  the

closing, near midnight, George Wintz signed a thick stack of  papers.  Among

these papers was a document entitled "Certified Copy of the Resolutions  of

the Combined Meeting of the Board of Directors and the Shareholders of  DGT

Properties, Inc." See, Knapp Deposition Exhibit 2, part of Ex.  118.  In  that

document, George L. Wintz identified himself as the sole shareholder of  DGT

Properties, Inc., and executed the document as sole director and sole

shareholder.  The document authorized the stock purchase and the  conveyance  of

the Territorial Road terminal as part of the purchase price.  When  it  later

came to light that this document was incorrect, George Wintz executed  an

affidavit asserting that on May 27, 1987, all the stock of DGT was  transferred

to Thomas G. Wintz, and that the certified copy of the resolutions  which

George Wintz had executed on June 19, 1987 was mistakenly  executed.  The

affidavit goes on to state that as of June 19, 1987, Thomas G. Wintz was  the

sole shareholder of DGT.

 

    36. The DGT corporate record book also contains a  document  entitled

"Combined Meeting of Board of Directors and Shareholders of DGT  Properties,

Inc.". This document is dated June 19, 1987, and contains  the  resolutions

which were discussed in the "Certified Copy of the Resolutions of the  Combined

Meeting of Board of Directors and the Shareholders of DGT Properties,  Inc."

which is part of the Knapp deposition.  This document is signed by  George  L.

Wintz as sole director, and Thomas G. Wintz as sole shareholder.  See, Ex. 114,

p. 24.

 

    37. On July 29, 1987, Gilbert Wiedenhoeft, of the  Department  of

Transportation, sent a letter to Space Center Transport, Inc., indicating  that

it had been reported to Mn/DOT that the IRCC, CHTR and LCC authority had  been

sold.  The letter requests Space Center Transport to  provide  certain

information to the Department regarding the sale and the new  owners.

 

    38. On August 4, 1987, Paul R. Knapp, corporate counsel for  Space  Center

Transport, Inc., replied to the Wiedenhoeft inquiry.  He indicated  that  the

authorities were not sold, but rather the corporate stock was sold.  He  went

on to say that the stock was sold "to DGT Properties, Inc., a company

controlled by Mr. George Wintz." Knapp sent a copy of the letter  to  Mr.

 

 

                                     -7-

 


Stanley C. Olsen, who Knapp identified as an attorney representing DGT

Properties, Inc. with regard to operating authority issues.  Ex. 32.

 

    39.  On August 11, 1987, Attorney Stanley C. Olsen sent a letter to Mr.

Wiedenhoeft.  The letter was written to "correct misstatements" contained in

the Knapp letter.  Olsen stated:

 

         Mr. George Wintz is not the control person of DGT

         Properties, Inc.  The sole shareholder and control person

         of DGT Properties, Inc. is Thomas Wintz.

 

Olsen sent a copy of this letter to Knapp, who was surprised by its contents.

Knapp had believed that George Wintz was the sole shareholder of DGT

Properties as a result of the document (Certified Copy of the Resolutions of

the Combined Meeting of Board of Directors . . ., Knapp Deposition Ex. 2,

described above) executed by George Wintz at the closing on June  19.  Upon

receipt of Olsen's letter, Knapp telephoned Olsen and confirmed the letter.

Knapp was concerned because the Territorial Road terminal had been transferred

to Space Center in the transaction.  Knapp wanted assurances that title to the

property was clear and that the person who had transferred the property  to

them (George Wintz) had authority to transfer it.  Knapp Deposition, p. 13.

 

 

Presidency of DGT

 

    40.  When DGT was first formed in May of 1986, George Wintz was elected

its first president.  He continued in that position for the remainder of 1986

and into 1987.  At the time of the June 19, 1987 closing discussed  above,

George Wintz was still the corporation's president.  Indeed, it  was  George

Wintz, and not Thomas Wintz, who participated in the closing.  Thomas Wintz

did not even attend.

 

    41. The corporate minute book contains a letter, dated July  15,  1987,

executed by George Wintz, whereby he resigned as president of DGT, effective

immediately.  The minute book contains a written action of the Board of

Directors dated July 16, 1987, indicating that Thomas G. Wintz was  elected

president of DGT.

 

    42.  The corporate minute book also contains an agreement between DGT and

George L. Wintz (hereinafter the "consulting agreement").  This agreement is

signed by Thomas Wintz as president of DGT.  Ex. 112.  It is  dated  July  1,

1987.  This date must be an error.  T. 386.  The correct  dates  for  George

Wintz's resignation and Thomas Wintz's election are July 15 and 16,

respectively.

 

 

Control of DGT After the AcquiAitions and Chanqe_of Officers

 

    43. On June 19, 1987, when DGT acquired the Space Center  businesses,

Thomas Wintz was still a college student.  He was not scheduled to graduate

until May 1988.  During the 1986-1987 winter, Thomas worked as a  computer

consultant for Opportunity Management Services.  He was assigned to Milbank

Freightways, where he was working with their computer.  He worked approximately

20 hours per month, on the Milbank computer, and continued that work through

the summer of '87, the fall of '87, and the winter of '87-'88.  He was still

doing it as of the date of the hearing (May 1988).  T. 275-77.

 

 

                                    -8-

 


    44. During the summer of 1987, Thomas Wintz did not go to  summer  school.

He resumed his studies, for his senior year, in the fall of 1987.  He  carried

a full load during the fall semester.  Some classes were day  classes,  some

were evening classes.  During the spring semester of his senior  year  (early

1988), he carried a 50 percent course load, made up of all evening  courses.

 

    45. In July of 1987, Thomas became the president and sole  officer  (and

sole director) of DGT.  In addition, he is the president of  Wintz  Freight

Systems, which is the actual company operating equipment relevant to  this

proceeding.  Thomas is also the president of Sterling Freight  Systems,  which

is dormant.

 

    46.  A review of the checks drawn on the account of DGT from July 15, 1987

onward indicates no change from past practices: George Wintz signed  all  of

them, and they reflect large transfers of money to himself, Wintz  Investment

Company, Debra Strom (George's daughter, and Thomas' sister), Craig Hallum,  a

local broker-dealer where George Wintz maintained his personal  investments,

payments on the condominiums (both in Roseville and Scottsdale), and  payments

to a construction company in connection with work done on a residential

investment belonging to Debra Strom.  Indeed, although the  record  contains

copies of checks and check registers from July of 1987 through March of  1988,

Thomas Wintz did not sign any of the checks.  They were all signed  by  George

Wintz.  Thomas Wintz was added as a signatory sometime in  1988.  T.  12b-27.

 

    47. On August 13, 1987, George Wintz issued a DGT check in the  amount  of

$210,000, payable to the Park Bank.  When asked about this, he  indicated  it

was to purchase a cashier's check for payment to Wintz Truck Leasing in  order

to reduce the $1.4 million note.  But he was not sure of  that.  T.  155-56.

There are numerous checks flowing between Wintz Truck Leasing and DGT,  and

none of them are cashier's checks.  When asked further about why  a  cashier's

check was needed in this case, he was unable to explain the reason.  T. 233-34.

Thomas Wintz had no knowledge of the check or its purpose.  T. 352.

 

    48. On February 5 and March 3, 1988, George Wintz signed and  issued  DGT

checks in the amounts of $20,000 and $15,000, payable to Merle's Construction.

These checks were for the purpose of paying for the repair of certain  real

property which Debra Strom was preparing to put up for sale.  T. lb6-70.  This

is supposedly a loan to Debra, but like the other loans, there is no  written

loan agreement or any evidence in the record of the purpose for the  payments.

She has not made any repayments.  Despite the fact that these were  issued  in

the winter of 1988, well after Thomas became the president of the company,  he

did not know the purpose of the two checks until he heard his father  testify

about them at the hearing.  T. 386-87.

 

    49.  In general, Thomas Wintz had no knowledge of the money flowing

between DGT, his father, other companies controlled by his father, and  to

third parties for payment of his father's obligations.  He did  not  routinely

review the checks either before or after issuance.  T. 128.  At  the  time  of

the hearing (May 1988), his accountants were still working on the income  tax

returns for DGT and his own personal return in an attempt to compute the

interest due to and from DGT, George Wintz and the other Wintz  companies.

T. 351-52, 356-64, 390-91.

 

    50. It was planned that Tom would take over control of the  DGT  checkbook

in June or July of 1988.  T. 86.

 

 

                                     -9-

 


    51. Despite George Wintz's control of the DGT checkbook, Thomas  Wintz  did

control the day-to-day, nuts-and-bolts of the trucking operation.  After the

company was "scaled down" as discussed earlier, Wintz Freight Systems had

between 20 and 25 trucks and 50 drivers.  Fifteen of them were employed on a

regular fulltime basis.  The customer base consisted of  one  large  house

account, at which 11 trucks were domiciled, and the remainder was miscellaneous

irregular route hauling for a variety of customers.  T. 291-93.

 

    52.  Thomas Wintz directly supervises all of the drivers.  He carries a

beeper with him so that he can be located.  He is responsible for collective

bargaining, grievances, and labor relations.  T. 295-99.

 

    53. Thomas Wintz handles customer relations, including the  preparation  of

bills.  T. 296-97.  He processes and  computes  the  payroll.  T.  294.  He

handles the checkbook of Wintz Freight Systems and authorizes payment on all

bills.  T. 300.  He oversees  maintenance  schedules.  T.  204-05.  A  fair

characterization of his activities, as compared with those of his father,

might be to characterize Thomas as the vice-president in charge of  operations,

while his father is the chief executive officer.  Neither of those titles are

legally correct, but they are accurate reflections of the division of labor

which has existed to date.  From the date of its formation through the  date  of

the hearing, George Wintz effectively controlled DGT Properties.

 

 

Qther Indicia of Control

 

    54.  2323 Terminal Road in Roseville is the administrative office of DGT

and its two subsidiaries, Wintz Freight Systems and Sterling Freight Systems.

This is also the location where George Wintz operates Wintz Truck Leasing.

George has provided Thomas with space, rent free.

 

    55. Maintenance for DGT's rolling stock is performed by  Wintz  Truck

Leasing.  The rolling stock is based (when not at a house account or

elsewhere) at the Wintz Truck Leasing facility.

 

    56.  DGT and Sterling Freight Systems have no employees.  Wintz Freight

Systems has a number of drivers, but otherwise has no employees other than

Thomas.  All administrative and clerical services are provided to DGT, Wintz

Freight Systems and Sterling Freight Systems, free of charge, by George Wintz

through his wholly owned management company, Opportunity Management Services.

These services include the preparation of Wintz Freight Systems'  payroll

checks, invoices, and all necessary secretarial services.  T. 98-99, 103-05,

and 295-98.

 

    57.  The secretarial support provided without charge is worth only

approximately $100 per month.  The clerical support amounts to only another

$100 per month.  The rent is worth between $200 and $500 per month.

 

    58.  Wintz Freight Systems receives $10,000 per month from Milbank

Freightways for the services of drivers and tractors to shuttle Milbank

trailers.  In addition, Wintz Freight Systems receives another  $10,000  a

month for the lease of approximately five trucks to Milbank.  T.  306-07.

 

    59.  DGT hired George Wintz as a management consultant in an agreement

dated July 1, 1987.  Ex. 112.  For ten years, DGT must pay George Wintz a

 

 

                                    .-1O-

 


percentage of its gross revenues in monthly installments.  For  the  first  five

years, he is to be paid five percent of the gross revenues; for the  sixth  and

seventh years, six percent; and for the eighth, ninth and  tenth  years,  seven

percent of the gross revenues.  In addition, he is to be reimbursed for all

reasonable expenses.  The agreement recognizes that he may continue other

business activities, and that it is not exclusive as to his time  or  services.

Finally, the agreement is not contingent upon any level of profitability of

the company.  In other words, George Wintz is entitled to receive  a  percentage

of the gross revenues regardless of whether or not the company  is  profitable.

For example, if the operations of Wintz Freight Systems are  consolidated  with

DGT, there are roughly $140,000 in monthly revenues.  T.  306-07.  At  the  rate

of five percent of gross revenues, George Wintz is owed $7,000  per  month,  or

$84,000 per year.  However, no payments have been made under the agreement.

While George Wintz initially spent between five and six hours per week

assisting Thomas, that has dropped, and now he spends only about ten hours  per

month.  Since this is less than was originally contemplated, George  and  Thomas

have agreed to renegotiate the consulting agreement to provide for remuneration

at an hourly rate, rather than as a percentage of gross revenues.  The

renegotiation has not yet taken place, so the rate has not yet been set.

T. 85-94 and 313.

 

   60. The consolidated income statement of  DGT,  Wintz  Freight  Systems  and

Sterling shows $140,000 in monthly revenues, and $131,100 in monthly  expenses.

If the free rent, secretarial service, clerical support and an estimate of  the

hourly value of George Wintz's consulting is added in,  the  expenses  increase

to $132,800.  This leaves a Ing forma net profit (before taxes) of $7,200.

T. 315.

 

 

Procedural-Historv

 

   61. On or about August 31, 1987, a Stock  Transfer  Reporting  Form  (Mn/DOT

Form 7059) was filed with the Department of Transportation.  Ex. 115.  It

indicates that Space Center, Inc. (Transferor) and DGT Properties, Inc.

(Transferee) did, on June 19, 1987, transfer shares of Wintz  Freight  Systems,

Inc. (f/n/a Space Center Transport, Inc.).  The form indicates that the

transferee did not hold or own any other certificate or permit  issued  by  the

Commission, but that it did own 100 percent of the stock in another permit

carrier, Sterling Freight Systems, Inc.

 

   62. On or about September 9, 1987, a joint petition for  transfer  of  local

cartage carrier authority was filed with the Department  of  Transportation  on

Mn/DOT Form 7046.  It indicated that Wintz Freight Systems,  Inc.  (f/n/a  Space

Center Transportation, Inc.) was the transferor, and Wintz Freight Systems,

Inc. was the transferee.  It indicated that Thomas G. Wintz was the  sole

officer, sole director and sole shareholder.  It indicated that transferee

presently held CHTR authority and IRCC authority, as well as ICC authority.

Ex. 116.

 

   63. On or about September 9, 1987, a joint petition for  transfer  of

irregular route common carrier permit authority was filed with  the  Department

on Form Mn/DOT 7048.  It indicates that the transferor is Wintz Freight

Systems, Inc. (f/n/a Space Center Transport, Inc.) and the transferee is  Wintz

Freight Systems, Inc.  It indicates that Thomas G. Wintz is  the  sole  officer,

sole director and sole shareholder of the transferee.  It indicates  that

 

 

                                    -11-

 


transferee presently holds LCC and CHTR authority, as well as interstate  motor

carrier authority.  In response to the question, 'Please list  if  stockholder

or partner in other permit or certificate", the answer is "no".  Ex.  117.

 

    64. At the request of the Board, new joint petitions were  filed.  On  or

about October 12, 1987, another joint petition for transfer of local  cartage

carrier authority was filed with the Department on Form Mn/DOT 7046.  This  one

indicates that the transferor is Space Center, Inc. and the transferee is  DGT

Properties, Inc.  It indicates that Thomas G. Wintz is the sole  officer,  sole

director and sole shareholder of transferee, and that the transferee  presently

holds IRCC and CHTR authority, as well as interstate authority.  Notice  of  the

proposed transfer was published in the Board's weekly calendar of October  16,

1987, with a protest date of November 5, 1987.  Protests were  received  from

four Protestants, and the matter was set for hearing on January 25 and

subsequent days, as part of a consolidated hearing involved not only the  LCC

authority, but also the IRCC, CSC and CHTR authorities.  Notice of that

consolidated hearing was published in the Board's calendar of December 18,

1987 and weekly thereafter.  However, on December 15, 1987, the  Protestants  in

the LCC part requested that they be permitted to withdraw their  protests.

 

    65. On or about October 12, 1987, another joint petition for  transfer  of

permit carrier authority (relating to the IRCC authority) was filed with  the

Department on Mn/DOT Form 7048.  This petition indicated Space Center,  Inc.  as

the transferor, and DGT Properties, Inc. as the transferee.  It  indicated  that

Thomas G. Wintz was the sole officer, sole director and sole shareholder  of

the transferee, and that the transferee presently held LCC and CHTR  authority,

as well as interstate motor carrier authority.  In response to  the  question,

"Please list if stockholder or partner in other permit or certificate",  this

form indicates that the answer is "no" with regard to Wintz Freight  Systems,

Inc., but it goes on to indicate that DGT Properties, Inc. owns 100 percent  of

the stock in Sterling Freight Systems, Inc., which holds CSC permit

authority.  Notice of this joint petition was published in the  Board's  weekly

calendar of October 16, 1987, setting a protest date for November 5, 1987.

Protests were received from three Protestants, and the matter was  scheduled

for hearing on January 25 and following days.  Notice of the hearing  was  given

in the Board's weekly calendar of December 18, 1987, and weekly  thereafter.

 

    66. The consolidated hearing was continued from its January date  in  order

to permit parties to discuss settlement.

 

    67. On February 19, 1988, the Commissioner of Transportation  filed  a

petition to intervene in the four proceedings in order to "present  evidence

and argument concerning the public interest and the appropriateness of the

Board's approval of the transfer petitions involved in these proceedings

pursuant to Minn.  Stat.  221.151." The transferees filed an objection  to  the

petition.  On March 10, 1988, the Administrative Law Judge issued  the  First

Prehearing Order, wherein he granted the Commissioner's petition to  intervene.

 

    68.  On March 28, 1988, a prehearing conference was conducted  by  telephone

call, and on March 29, 1988, the Administrative Law Judge issued the  Second

Prehearing Order resolving various discovery disputes.  As a part  of  this

Order, a Protective Order was entered to protect certain information which  was

claimed to be proprietary information or trade secret.

 

    69. The consolidated hearing included petitions to transfer  IRCC,  LCC,

CHTR and courier authority.  However, by the start of the hearing  in  May,

 

 

                                    -12-

 


1988, the joint petitioners had withdrawn the courier permit and charter

permit petitions, leaving only the IRCC and LCC petitions at issue.  And with

regard to those two petitions, by the time of the start of the hearing, all

Protestants had withdrawn their protests, subject to the adoption of a

restriction to the IRCC authority.  T. 7 and 34.

 

 

                         PERTINENT STATUTORY EXCERPTS

 

   Minn.  Stat.  221.151, subd. 1 (1986) provides, in pertinent part:

 

         Permits, except livestock permits, issued under  section

         221.121 may be assigned or transferred, but only upon the

         order of the board approving the transfer or  assignment

         after notice and hearing.

 

 

 

         Provided, however, that the board shall make no order

         granting the sale or lease of a permit to a person or

         corporation or association which holds a certificate  or

         permit, other than local cartage carrier permit, from the

         board under this chapter or to a common carrier by  rail.

 

 

 

         If an authority to operate as a permit carrier is held by a

         corporation, a sale, assignment, pledge, or other transfer

         of the stock interest in the corporation which will

         accomplish a substantial or material change or transfer of

         the majority ownership of the corporation, as  exercised

         through its stockholders, must be reported in the  manner

         prescribed in the rules of the board within 90 days after

         the sale, assignment, pledge or other transfer of  stock.

         The board shall then make a finding whether or not the

         stock transfer does, in fact, constitute a sale, lease, or

         other transfer of the permit of the corporation to a  new

         party or parties and, if they so find, then the continuance

         of the permit issued to the corporation may only be  upon

         the corporation's complying with the standards and

         procedures otherwise imposed by this section.

 

   Based upon the foregoing, the Administrative Law Judge makes the following:

 

                                 CONCLUSIONS

 

   1.  The Transportation Regulation Board has jurisdiction over the subject

matter of the hearing.

 

   2.  Proper notice of the hearing was timely given, and all relevant

substantive and procedural requirements of law or rule have been fulfilled

and, therefore, the matter is properly before the Administrative Law Judge.

 

   3.  There is no legal bar to the transfer of the local cartage carrier

permit (LCC 596) at issue in this proceeding.  There are no remaining

 

 

                                    -13-

 


Protestants and the Commissioner has not  made  any  showing  of  noncompliance.

The tests of Minn.  Stat.  221.296, subd. 8 have been met with one

exception -- the notice of the stock transfer was  not  given  within  30  days.

However, this is deemed to be directory, not jurisdictional.  See, Memorandum.

 

    4.    With regard to the IRCC transfer, the sale of  the  stock  interest  in

Wintz Freight Systems, Inc. did accomplish a substantial or material change or

transfer of the majority ownership of the corporation to a new party or

parties within the meaning of Minn.  Stat.  S  221.151.  Wintz  Freight  Systems,

Inc. is, therefore, required to comply  with  the  standards  and  procedures

imposed by Minn.  Stat.  221.151.

 

    5.    The Transportation Regulation Board is  prohibited  from  issuing  an

Order granting the sale of a permit to a corporation which holds a certificate

or permit.  The Board has appropriately  interpreted  the  statute  to  extend  to

situations involving the transfer of a permit to a corporation which is owned

or effectively controlled by an individual  with  a  pre-existing  interest  in

another certificate or permit (other  than  local  cartage  carrier  permit).

Petition of Fritz Truckinq, Inc., 407 N.W.2d 447 (Minn.  App. 1987).

 

    6.    DGT Properties, Inc., being effectively  controlled  by  George  L.

Wintz, Jr., does not comply with the standards of Minn.  Stat.  221.151

because George L. Wintz, Jr. also  effectively  controls  Wintz  Truck  Leasing,

which already holds contract carrier  permit  authority  and  charter  permit

authority.

 

    7.    The appropriate test for determining whether George L. Wintz,

Jr.'s control of Wintz Truck Leasing Co. ought to be attributed to DGT

Properties, Inc. is not the traditional  "pierce  the  corporate  veil"  test

used to determine a shareholder's  financial  liability  for  corporate  debts.

Instead, the appropriate test is the plain meaning of the "effectively

controls" test of Fritz.  Effective control means the ability to direct

the management and policies of a corporation.  The  question  is  one  of  fact,

to be determined not by any artificial test,  but  rather  from  the  particular

circumstances of each case.  It is  a  complex  question  requiring  appraisal  of

the overall effect of various relationships between individuals and other

circumstances present in a particular case based  upon  the  realities  of  the

situation.

 

THIS REPORT IS NOT AN ORDER AND NO AUTHORITY IS GRANTED HEREIN.  THE

TRANSPORTATION REGULATION BOARD WILL ISSUE THE  ORDER  OF  AUTHORITY  WHICH  MAY

ADOPT OR DIFFER FROM THE FOLLOWING RECOMMENDATIONS.

 

    Based upon the foregoing, the Administrative Law Judge makes the following:

 

                                 RECOMMENDATIONS

 

    1.    That the joint petition to transfer local cartage carrier permit

authority be GRANTED.

 

    2.    That the joint petition to transfer  irregular  route  common  carrier

permit authority be DENIED; or, in the alternative, that it be GRANTED,

SUBJECT TO such conditions as the Board may  prescribe  to  ensure  that  the

operations of DGT Properties, Wintz Freight  Systems  and  Sterling  Cartage  are

 

 

                                      -14-

 


separated and isolated from those of George L. Wintz, Jr. within a  reasonable

period of time.  See, Memorandum.

 

                 

Dated this 28th  day of September, 1988.

 

 

 

                                         ALLAN W. KLEIN

                                         Administrative Law Judge

 

 

                                    NOTICE

 

    Pursuant to Minn.  Stat.  14.62, subd. 1, the agency is required to  serve

its final decision upon each party and the Administrative Law Judge by  first

class mail.

 

Reported:  Tape Recorded, Transcribed by Mary Ann Hintz.

 

 

                                  MEMORANDUM

 

                                      I.

 

    Alternative recommendations are made because there is nothing  illegal

about what the Wintzes are trying to accomplish -- the father is trying to

help the son get set up in business for himself.  The law does  not  prohibit

this.  The problem arises because George Wintz started about a year too

early, while Thomas was still in college.  Thomas was unable  to  participate

in the formation of DGT, in the acquisition of the Space Center  businesses,

and in the restructuring of those businesses into a manageable size for  him

to operate.  All that was done by George Wintz, with Tom either totally

absent or very much on the sidelines.  There is no question but  that  from

the formation of DGT to the date of the hearing, George Wintz controlled  DGT.

In late May of this year, however, Thomas graduated from college, and is  now

able to devote his full energies to the businesses.

 

    The purpose of the law would be served if Thomas Wintz were forced  to

modify DGT's relationship with his father, so that Thomas controlled DGT  in

fact, as well as in name.  There is nothing in the law that  prohibits  members

of the same family holding permits, so long as they are truly independent  of

each other.

 

    The Board has the particular expertise to fashion the specifics of how

the two ventures ought to be separated, as well as to set reasonable  time

periods to accomplish the details.  Such conditions could relate to the

sharing of common services and facilities, the repayment of advances and

debts, prohibitions against future operational and financial  entanglements,

and such other reasonable conditions as the Board might require in order

to ensure that the operations are kept independent of one another.  The  goal

is to make sure that George Wintz is not in control of DGT and its

subsidiaries.

 

 

                                    -15-

 


                                      II.

 

    One of the issues in this case is what test should be used to  determine

who "effectively controls" DGT and Wintz Freight Systems.   Counsel for DGT

urges that the test for "piercing the corporate veil" to determine  individual

liability for corporate debts ought to be the test used here.  See, for

example, Victoria Elevator Co. v. Meriden Grain Co., 283 N.W.2d 509 (Minn.

1979).  On the other hand, counsel for the Commissioner urges that the

appropriate test is that derived from plain language and common usage of  the

word "control".

 

    The Commissioner's position is the correct one.  In determining  whether  or

not a person effectively controls a corporation, each case must be  determined

on its own facts.  Relationships between individuals must be assessed and

evaluated, and the past history of corporate decision-making must be  analyzed,

not only in terms of form, but also in terms of substance.  It boils  down  to

deciding, as a practical matter, who was able to direct the management of  the

corporation.

 

 

 

    There can be no serious question but that George Wintz controlled DGT

Properties from the time of its inception up to the date of the  hearing.  He

decided who it would do business with, he decided on what terms and  conditions

it would enter into contracts and arrangements, and he determined its size  and

shape.  The various transfers of money to and from DGT  dramatically  evidence

his total dominion and control, both before and after the transfer of  stock

from father to son.

 

    In conclusion, there is nothing wrong with George Wintz setting his son  up

in business.  The problem in this case arises because he started  too  early,

and, as of the date of the hearing, he still had not relinquished control  to

his son.  The only way in which the Board can allow the transfer to  take  place

is if it can be assured that George Wintz will not control DGT and its

subsidiaries.  One way to achieve such assurance is to impose a list of

conditions, and a timetable for their completion.  Otherwise, the  Board  must

deny the transfer.

 

                                      IV.

 

    The LCC permit transfer is governed by a different statute than the  IRCC

permit transfer.  The IRCC transfer statute requires notice of a stock

transfer within 90 days thereafter.  The LCC transfer statute  requires  notice

within 30 days of the transfer.  The notice given was, at best, given on

August 5 or 6, which is 48 or 49 days after June 19.  The exact  receipt  date

of Ex. 32 is unknown.

 

    There is no penalty specified in the statute for failure to give  timely

notice, and no party to this proceeding has suggested that the failure to  give

timely notice deprived the Board of jurisdiction over the transfer.  Under  the

circumstances, the delay is a harmless error.

 

                                    A.W.K.

 

 

 

                                    -16-