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issue, HJA filed consolidated Federal income tax returns with its
subsidiaries. The consolidated group is the petitioner in docket
No. 22920-97.
During all relevant periods, members of the Misle family
operated motor vehicle dealerships (the Misle dealerships) and
related businesses (collectively the Misle group). The Misle
dealerships were located on the north and south sides of O Street
in Lincoln, Nebraska. Until 1990, the three Misle brothers–-
Henry, Abram Misle (Abram or AM), and Julius Misle (Julius or
JM)–-were the primary family members involved in the operation of
the Misle dealerships. Henry controlled and operated the
dealerships on the south side of O Street through a corporation,
Misle Chevrolet & Imports, Inc. (Chevrolet), and Abram controlled
and operated the dealerships on the north side of O Street
through a corporation, Park Place Pontiac-Cadillac-GMC, Inc.
(Park Place). Julius operated other businesses in the Misle
group.
B. The 1986 Reorganization
Before 1986, the Misle group operated through various
partnerships and corporations, ownership of which varied from
entity to entity. Effective August 14, 1986, the Misle group was
reorganized under a unified corporate structure (the
reorganization). A new holding company, HJA, and several
subsidiary corporations, wholly owned either directly or
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