- 3 - FINDINGS OF FACT Introduction Some of the facts have been stipulated and are so found. The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference. At the time of the filing of the petitions in these cases, the principal places of business of all petitioners were in Ohio. The Commonly Owned Group Petitioners are members of a commonly owned group of 14 corporations (the group). Except for one member of the group, BKK Management, Inc. (BKK), each member of the group either owns and operates one or more Taco Bell restaurants or owns the real estate on which another member of the group operates a Taco Bell restaurant. BKK provides management and administrative support services to the other 13 members of the group. During the years at issue, each member of the group was owned in equal shares by George L. Kentris (G. Kentris), Michael N. Kentris (M. Kentris), and Kenneth J. Baerwaldt (Baerwaldt), either individually or together with their spouses. Messrs. G. Kentris, M. Kentris, and Baerwaldt were also the directors and managing officers of each member of the group (collectively, the owner-managers). BKK Management, Inc. BKK was established as a “cost company”, to provide management and administrative support services to the other members of the group (the purchasing members) at cost. Among thePage: 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