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dealership); and Foretravel of Texas, Inc. (the Texas
dealership), which apparently included two separate dealerships,
one located in Dallas and the other located in Nacogdoches. We
refer to the dealers collectively as subsidiaries or dealerships.
Moore served as president of the subsidiaries and the Arizona
dealership. IIG owned the dealerships' stock because petitioner
wished to avoid the appearance that it sold its coaches through
factory-owned dealers. IIG and the subsidiaries filed
consolidated returns in 1989 based on a December 31 calendar
year. In 1990, IIG was liquidated, and petitioner acquired the
dealerships' stock. The subsidiaries filed separate returns in
1990 based on a calendar year ending December 31.
The Pacific Northwest Dealership
In 1980, Walter P. Nicholson (Nicholson) and William H.
Fishfader (Fishfader) became partners in a Toyota agency in Coeur
d'Alene, Idaho, where they sold motor homes, recreational
vehicles, and automobiles. In 1983, they decided to sell
recreational vehicles full time and became interested in the
Foretravel product line. They contacted a Foretravel
representative on the West coast and eventually signed a dealer
agreement with Foretravel on August 15, 1983, that enabled them
to be the exclusive dealer of Foretravel products for a 5-year
period in Idaho, Montana, Oregon, and Washington. Pursuant to
the agreement, Fishfader and Nicholson also could sell less
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