- 4 - Kirkham--23 percent; J. Kirkham--18 percent; M. Kirkham--18 percent; and L. Sponenburgh--18 percent. At all relevant times, Kapsco was a going concern. Kapsco operated 10 retail stores in fiscal year 1991 and 9 retail stores in fiscal year 1992. Kapsco's retail stores during those years were primarily located in eastern Idaho and included the following: (1) Blackfoot; (2) Driggs; (3) Idaho Falls-- Milligan; (4) Idaho Falls--Park; (5) Montpelier; (6) Pocatello; (7) Rigby; (8) Shelley; (9) American Falls; and (10) Rexburg. The retail stores were not separately incorporated. In order to expand their sales base, the Kirkham family organized Kaps Automotive Warehouse, Inc. (KAW), in 1979. During the years at issue, KAW's shareholders and their respective percentage ownership interest were as follows: Petitioner--25 percent; J. Kirkham--25 percent; M. Kirkham--25 percent; L. Sponenburgh--25 percent. At all relevant times, KAW was a going concern. In 1979, KAW acquired Nordling Parts Co. of Twin Falls (NPC). (Although KAW acquired 100 percent of NPC's stock, NPC's original income tax returns for fiscal years 1991 and 1992 indicate that KAW owned only 75 percent of NPC's stock.) NPC was KAW's jobber (or retail) store. At all relevant times, NPC was a going concern. During the years at issue, the officers of petitioner, Kapsco, NPC, and KAW were: M. Kirkham--president; J. Kirkham--vice president; and W. Sponenburgh--secretary.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