Southern Boiler Sales & Service, Inc. - Page 3

                                        - 3 -                                         
          No. 2 was the same as that of petitioner.  The parties now agree            
          that petitioner and No. 2 are really one corporation, and the               
          notice of deficiency generally has combined the gross receipts,             
          costs of sales, income, and deductions reported on the corporate            
          tax returns of the two.                                                     
               Petitioner had seven employees, five of whom, including                
          Berry, were technicians.  The technicians worked at the                     
          customers' sites.                                                           
               Since its inception, petitioner has leased property owned by           
          Berry and his wife (the property) for its offices and parts                 
          department.  Prior to petitioner's use of the property, it had              
          served as the Berrys' personal residence.  The property consists            
          of a 2,031-square-foot house and two storage sheds (70 and 130              
          square feet, respectively) on three-quarters of an acre of land.            
               Petitioner stored pipefittings and insulation in the two               
          sheds.  Welding equipment and a pipe rack stood outside.  The               
          gravel driveway was large enough to park nine vehicles, including           
          a van and a 1-ton truck.  Generally, four or five vehicles would            
          be parked there for some period during a normal business day.               
          Petitioner had no identifying signs on the property other than              
          those on the truck when it was parked there.  The property had a            
          well and septic system and was not served by city water or sewer.           
               The property is located on Neelley Road in Pleasant Garden,            
          North Carolina.  During the years at issue, Pleasant Garden was a           
          rural community that was becoming increasingly suburban, with the           




Page:  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