- 3 - 1945 as a "jobber"1 of automotive parts. At all relevant times, petitioner's operations comprising petitioner, one other related wholesale warehouse, and 24 related retail stores. Each of the related entities to which petitioner sold merchandise was a separate legal entity. Petitioner also sold merchandise to unrelated entities. During the years at issue, petitioner's stockholders and their respective percentage ownership interests were as follows: Michael Kirkham (M. Kirkham)--25 percent; James Kirkham (J. Kirkham)--25 percent; Linda Sponenburgh (L. Sponenburgh)--25 percent; and O. Reed and Ruth Kirkham (O.R. and R. Kirkham)--25 percent. M. Kirkham, J. Kirkham, and L. Sponenburgh are the children of O.R. and R. Kirkham, and William Sponenburgh is the husband of L. Sponenburgh. Petitioner's Related Entities Petitioner's related entities purchased approximately 95 percent of their merchandise from petitioner. The Kirkham family formed Kirkham Auto Parts Service Co. (Kapsco), an S corporation, in the early 1960's. During the years at issue, Kapsco's shareholders and their respective percentage ownership interests were as follows: O.R. Kirkham--23 percent; R. 1 In the terminology of the industry, a jobber of automotive parts purchases automotive parts from a warehouse distributor or manufacturer and sells the parts to installers (such as a service station) or to retail stores which then sell the parts to the consumer.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