- 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 thePage: 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