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business activities except for petitioner's law practice and Hall
Farms were carried on in the form of Oklahoma corporations.
Concordia, Six Drilling, Stroud Land, Stroud Builders,
Preferred, Brazos, Empire, Paramount Farms, Service Rig,
Paramount Oil, and Petron are hereinafter sometimes referred to
collectively as the Corporations.
Concordia was involved in rental properties, and had a
corporate bank account. Six Drilling was involved in drilling.
Both Stroud Land and Stroud Builders were involved with the Oak
Brook Estates addition to Stroud, Oklahoma, a housing
development; each took out loans to finance this development, and
each had a bank account. Preferred was an alarm system company
operating out of Norman, Oklahoma. Brazos operated one drilling
rig, and also took out a $50,000 loan. Empire drilled for oil,
owned five drilling rigs, owned a shop building that Empire took
out a loan to finance, and also took out at least one other loan.
The record does not indicate what type of business Paramount
Farms was involved in, but it was in existence throughout the 5-
year period in issue, although its status was suspended for about
15-1/2 months in 1984-1985. See infra table 1. Service Rig was
involved in salvaging drilling rigs. Paramount Oil had a
corporate bank account; it had some expenses that were deducted
on one or more of petitioner's tax returns. Petron was formed to
engage in oil and gas and real estate businesses; it paid taxes.
Each of the Corporations had its corporate charter suspended
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