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for the lease from Bison Leasing Co. of certain computer
hardware. This lease was eventually assigned to the Fleet Credit
Corp./Denrich Leasing Group. The computer hardware was leased
for the sole benefit of and use by Mr. Kelley. From March 21,
1988, through January 31, 1991, petitioner paid $9,565 under this
lease.
On September 14, 1989, petitioner executed a lease with
Active Leasing, Inc., for a 1990 Plymouth Acclaim automobile for
Mr. Kelley's use. This lease was eventually assigned to Bank One
of Akron. During Mr. Kelley's use of the vehicle, petitioner
paid $7,787 in connection with this lease.
On April 5, 1990, petitioner entered into a 3-year lease
agreement with James-McGuire Associates for the lease of certain
computer hardware. This lease was eventually assigned to Orix
Credit Alliance. This computer hardware was also leased for Mr.
Kelley's use. From April 5, 1990, through January 31, 1991,
petitioner paid $13,873 under this lease.
The initial entity formed for the development and production
of the computer program was Transnational Information Controls,
Inc. (TIC). TIC was incorporated under the laws of the State of
Ohio on January 26, 1989. Petitioner owned 50 of the 764
outstanding shares of TIC. Petitioner provided legal services to
TIC in exchange for his TIC stock.
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