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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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