Kenneth M. and Delores J. Hairston - Page 2




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               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 to                     
















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