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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.
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