Crop Care Applicators, Inc. - Page 3

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               Respondent determined deficiencies of $9,821, $9,127, and              
          $6,166 in petitioner’s Federal income taxes for taxable years               
          1995, 1996, and 1997, respectively.  After concessions,1 the sole           
          issue for decision is whether petitioner is entitled to credits             
          for Federal tax on fuels pursuant to sections 34 and 6420.                  
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by reference.  At the time the petition was             
          filed in this case, petitioner was a corporation organized in the           
          State of California.  During the years in issue, petitioner’s               
          principal place of business was Shafter, California.  William A.            
          Duncan (Mr. Duncan), president and sole shareholder of                      
          petitioner, signed the petition and appeared at trial on behalf             
          of petitioner.                                                              
               Petitioner is an agricultural chemical application company             
          that applies pesticides to various farms and orchards in                    
          California.  The pesticides are applied by tractor-pulled spray             
          rigs.  Petitioner enters into either verbal or written service              
          contracts with its customers depending on the size of the farming           
          operation.  Petitioner supplies its customers with a cost sheet             

               1  The parties stipulated that respondent correctly reduced            
          petitioner’s taxable income for tax years 1996 and 1997 and,                
          correspondingly, correctly adjusted petitioner’s claimed net                
          operating loss amount for 1997.                                             

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Last modified: May 25, 2011