- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue. FINDINGS OF FACT The parties have stipulated some of the facts, which are so found. When they filed their petition, petitioners resided in Tulsa, Oklahoma. Since 1985, petitioners have owned and operated Hairston, Inc. (Hairston), a subchapter C corporation engaged in the business of leasing heavy construction equipment to third parties. During 1995 and 1996, petitioners were employed full time by Hairston. During 1993 through 1996, petitioners purchased in their names eight pieces of heavy construction equipment (petitioners’ equipment). They leased this equipment to Hairston, which subleased petitioners’ equipment to its customers (end users). Petitioners entered into a written lease agreement with Hairston reflecting the lease of petitioners’ equipment toPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011