- 6 - 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 lessPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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