- -4
During petitioner's fiscal year 1990, Gillette Tire was in
the business of selling and recapping tires. For its fiscal year
ending March 31, 1991, Gillette Tire filed a consolidated tax
return with A&A. Gillette Tire derived a substantial portion of
its income from the sale of truck tires and tire-related services
to unrelated third parties.
In June 1987, petitioner signed a lease agreement with
Nikki's Leasing Corp. (Nikki's) to lease ready-mixed concrete
trucks (the Nikki lease). Kurt Caillier established Nikki's and
other leasing companies in 1987 to lease trucks to the Caillier
family's related companies. These companies were owned by
children of Kurt and Randy Caillier but controlled by Kurt and
Randy Caillier. During petitioner's fiscal year 1990, Kurt
Caillier was the president of both petitioner and Nikki's.
During its fiscal year ending June 30, 1990, petitioner
leased trucks from Nikki's pursuant to the Nikki lease. In 1990,
petitioner had on lease from Nikki's 48 trucks. The number of
trucks used by petitioner fluctuated from day to day. If
petitioner needed additional trucks, it would use available
trucks of related companies and sometimes would rent trucks from
unrelated sources. In 1990, petitioner did not own any concrete
trucks.
In 1990, Mr. Chris Pisano (Mr. Pisano) was petitioner's
general manager. As general manager, Mr. Pisano ran the daily
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