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that operated as a bulk carrier of liquid and dry chemicals.4
Some of the chemicals that Central hauled were toxic. Central
transported bulk chemicals in tanker trailers pulled by tractors.
Central held operating authorities issued by the ICC,
various States, and Canada. These authorities granted Central
contract and common carrier status for the transportation of bulk
chemicals, including liquid or dry toxic chemicals, in tanker
trailers between points and places within the United States,
various States, and Canada. Central faced minimal competition
because of the expensive equipment required to engage in the
tanker trucking business.
Central was an S corporation.5 Central was highly
successful in its bulk chemical hauling business, realizing net
ordinary income from 1991 through 1996 as follows:
Year Amount
1991 $2,399,057
1992 2,321,825
1993 3,242,161
1994 8,239,741
1995 7,043,522
1996 6,046,232
Total 29,292,538
4Central sold substantially all its operating assets and the
right to operate under the name of Central Transport, Inc., in
1997. After the sale, Central ceased its motor carrier
operations and changed its name to Honbarrier, Inc.
5An S corporation generally pays no income tax. Rather, the
corporate income is taxed to the shareholders on a pro rata
basis. See sec. 1366.
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