- 4 -
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners lived in San Antonio, Texas, when they filed
their petition.
During the years in issue, petitioner was sole proprietor of
Allied Electric and Air Conditioning Co. (Allied Electric)
located on Hoefgen Avenue (Hoefgen Avenue property) in San
Antonio. There was a billboard and a commercial sign (the two
outdoor advertising signs) on the Hoefgen Avenue property.
Petitioner bought the following vehicles for Allied
Electric because he thought he needed them for contracts on which
he had bid, but which he did not win:
Vehicle Date acquired
1973 Ford Digger October 1982
1972 Ford Bucket truck February 1983
1977 GMC Bobtail April 1983
1977 GMC Bobtail April 1983
1985 Ram Charger October 1984
He maintained them, but he did not register or insure them until
he began to use them for his business in 1985.
B. The Hoefgen Avenue Property
1. Addition of Storage Space and Office
Between January 1, 1982, and December 31, 1984, petitioner
added warehouse storage space and an office addition to the
second story of the Hoefgen Avenue property. Richard Zamora
(Zamora) drafted plans for the storage space addition in November
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011