- 2 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of fact and the exhibits thereto are incorporated herein. The Cleveland Trencher Co. (petitioner) is an Ohio corporation whose principal place of business was in Cleveland when the petition was filed. Petitioner is an accrual basis taxpayer. Petitioner, established in 1904, is in the business of manufacturing and selling trenching machines (also called ditching machines or trenchers). Trenchers are tractorlike machines used to dig ditches for pipelines, irrigation channels, and other purposes. A corporation called A-A-H International Trading Co., Inc., was incorporated in Ohio in 1984 "To operate an export, import business and any lawful act or activity for which corporations may be formed under * * * Ohio" law. Its corporate charter was revoked in 1985. On October 13, 1986, petitioner entered into an agreement (the first commission agreement) with "AA&H International" (AA&H); the agreement was executed on behalf of AA&H by Metin Aydin (Mr. Aydin). On March 2, 1987, petitioner entered into another agreement (the second commission agreement) with AA&H and Mr. Aydin. The second commission agreement called for paymentsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011