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employees. Petitioner decided to become more involved at the
dealer level and, in 1979, petitioner took over a dealership in
California (the California dealership) that owed petitioner
money.
The Fores traveled to California to run the California
dealership, and they managed to boost sales from 3 coaches a
month to over 20 a month. The Fores continued to operate the
California dealership until the middle of 1980 when they returned
to Nacogdoches, Texas. Due to the success of the California
dealership, petitioner purchased other dealerships in Texas,
Tennessee, and Florida. In each case, these other dealerships
were existing businesses that sold other vacation vehicles, such
as trailers and inexpensive motor homes, in addition to selling
Foretravel coaches. The California dealership was the only
dealership suffering financial problems when purchased by
petitioner.
By 1989, petitioner owned 100 percent of the stock of
Foretravel of Arizona, Inc. (the Arizona dealership), but the
Arizona dealership closed in 1989 following a change in Arizona
State law. Petitioner also owned 100 percent of the stock of
Investments in General, Inc. (IIG). IIG had four wholly owned
subsidiaries: Foretravel of California, Inc. (the California
dealership); Foretravel of Florida, Inc. (the Florida
dealership); Murphy Motor Manors, Inc. (the Tennessee
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