Harry E. Peaden, Jr. - Page 3




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          covering transactions entered into by Country-Fed Meat Co., Inc.            
          (Country-Fed), a subchapter S corporation wholly owned by                   
          petitioner Harry E. Peaden, Jr. (petitioner) and (2) whether such           
          agreements should be treated as leases or purchases of trucks.              
                                  FINDINGS OF FACT                                    
               Some of the facts and certain exhibits have been stipulated            
          for trial pursuant to Rule 91.  The parties' stipulations of fact           
          are incorporated into this Opinion by reference and, accordingly,           
          are found as facts in the instant case.                                     
               At the time they filed the petition, petitioners resided in            
          Fayetteville, Georgia.  Petitioner is the sole shareholder of               
          Country-Fed, a corporation that was incorporated under the laws             
          of the State of Georgia.  Petitioner elected, before 1993, to               
          have Country-Fed taxed as a small business corporation pursuant             
          to section 1362(a).                                                         
               Country-Fed is in the business of selling meat, chicken, and           
          seafood products through direct sellers.  Country-Fed's direct              
          sellers distribute Country-Fed's products in approximately 20               
          States.                                                                     







          1(...continued)                                                             
                    upon sale or other disposition of such property.                  




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