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Monaghan Leasing Co.
Monaghan is a leasing corporation owned by petitioner and
Dickman; petitioner was its president. Monaghan acquires
construction and other equipment and leases it to CDI and the
other enterprises. Monaghan had no employees in 1990 and 1991.
Throughout the years at issue, the offices of CDI and
petitioner's other businesses were all located in a single office
suite at Allison Pointe, in one of the buildings owned by the
partnerships. Petitioner occupied one office in this suite from
which he conducted all of his business activities. Petitioner
stated that "if you walked into our office there wouldn't be
divisions between each of these companies and it would be
difficult for you to tell who worked for who". The businesses
all shared the same phone lines. Rent was allocated among the
businesses based on a square-foot analysis of the space each
business utilized. None of the cost of the space, however, was
allocated to the partnerships.
Expenses for all of the above-described entities were
generally paid through CDI. This was viewed as the most
efficient way to handle accounting and invoicing for the entities
collectively. Expenses were then generally allocated to a
specific company or partnership by CDI's accounting department.
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