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incorporate by reference the stipulation of facts and attached
exhibits.
Background
Petitioner is Foretravel, Inc. (Foretravel), a corporation
organized in 1968 under the laws of the State of Texas, with its
principal place of business in Nacogdoches, Texas. During the
years in issue, petitioner filed its tax returns on a June 30
fiscal year basis. Petitioner manufactured and sold class A
self-contained motor homes (coaches) ranging from 29 to 40 feet
in length. Petitioner sold its coaches under the trade names of
Grand Villa and Unihome. The Grand Villa sold for retail prices
from $103,000 to $245,000, while the Unihome sold for retail
prices from $172,000 to $310,000.
Foretravel personnel included the following: Clarence M.
Fore (Mr. Fore), president; Don Franklin (Franklin), vice
president and chief financial officer; James Don Moore (Moore),
vice president and general manager; Ruth Marie Fore (Mrs. Fore),
secretary and treasurer; Bill Weaver (Weaver), comptroller and
assistant treasurer; and Floyd Wilcox (Wilcox), director of
marketing operations. Mr. Fore spent his time designing and
selling coaches, while Moore essentially ran petitioner's
operations until his death in 1993.
Mr. Fore built his first motor home in his spare time in
1967 and incorporated Foretravel one year later to manufacture
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