- -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 dailyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011