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divisions and certain “other entities”. The “other entities”
were Pioneer Ford Sales, Inc. (Pioneer), Fiesta Lincoln-Mercury,
Inc. (Fiesta Lincoln), Heritage Auto Center, Inc. (Heritage),
Fiesta Dodge, Inc. (Fiesta Dodge), Sunland Ford, Inc. (Sunland),
Imports of Albuquerque, Inc. (Imports), Deep Seal International,
Inc. (Deep Seal), Horizon Life Insurance Co., Inc. (Horizon),
Ranch Partnership (Ranch), Valley Ford Sales, Inc. (Valley),
Warranty Protection Co., Inc. (Warranty), Theft-Shield
International, Inc. (Theft-Shield), and Arizona Aftermarket
Associates, Inc. (Aftermarket).
Pioneer, Fiesta Lincoln, Heritage, Fiesta Dodge, Sunland,
and Imports each owned and operated dealerships for the sale of
new automobiles and trucks. Deep Seal provided paint sealant to
be applied on new vehicles at the time of sale. Horizon sold
credit life insurance on financed vehicles at the time of sale.
Theft-Shield provided theft protection for new vehicles.
Warranty provided extended service warranties for new vehicles at
the time of sale. Valley and Aftermarket provided accessory
parts for new vehicles at the time of sale. Ranch owned and
operated a large cattle ranch.
Petitioner had an ownership interest in each of the other
entities, except Sunland. Petitioner was a special trustee of a
business trust which owned Sunland. Petitioner’s interest in the
other entities varied from 15 percent of Warranty to 100 percent
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