Estate of Leon Spear, Deceased, Jeanette Spear, Harvey Spear and Robert Spear, Administrators, and Jeanette Spear - Page 15

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               2(...continued)                                                        
                    (b)  During the years 1975, 1976 and 1977,                        
               petitioners owned and controlled two corporations known                
               as Ezy Parks, Inc. and Tumble Down, Inc.                               
                    (c)  Ezy Parks, Inc. was incorporated in                          
               Pennsylvania on December 26, 1956 and at all times was                 
               wholly owned and controlled by petitioners.                            
                    (d)  Tumble Down, Inc. was incorporated in                        
               Pennsylvania on December 18, 1958 and was at all times                 
               wholly owned and controlled by petitioners.                            
                    (e)  During the years 1975, 1976 and 1977, Ezy                    
               Parks, Inc. and Tumble Down, Inc. each leased numerous                 
               parking lots which they in turn operated and managed                   
               [in] a business whereby cash fees were received from                   
               customers who parked their cars on the parking lots                    
               operated by Ezy Parks, Inc. and Tumble Down, Inc.                      
                    (f)  Ezy Parks II, Inc. was incorporated on                       
               November 13, 1975 in Pennsylvania and was at all times                 
               wholly owned and controlled by petitioners.                            
                    (g)  Ezy Parks II, Inc. was also engaged in the                   
               operation and management of parking lots and received                  
               cash fees from customers who parked their cars on these                
               lots.                                                                  
                    (h) Petitioner Leon Spear supervised and managed                  
               the operations of Ezy Parks, Inc., Tumble Down, Inc.                   
               and Ezy Parks II, Inc. during the taxable years 1975,                  
               1976 and 1977.                                                         
                    (i)  The parking lots operated and managed by                     
               petitioners through their wholly owned corporations                    
               were businesses in which receipts from customers were                  
               predominantly in cash.                                                 
                    (j)  Petitioner Jeannette Spear maintained the                    
               business records and handled the banking transactions                  
               for Ezy Parks, Inc, Tumble Down, Inc. and Ezy Parks II,                
               Inc. during the taxable years 1975, 1976 and 1977.                     
                              *   *   *   *   *   *   *                               
                                                             (continued...)           



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