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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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Last modified: May 25, 2011