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Regal sold new mobile homes either from inventory located at
its business premises or from orders placed with mobile home
manufacturers. Regal also sold and traded used mobile homes.
Mobile homes are transported on detachable wheels and axles.
Upon the sale of a mobile home, a set-up crew provided by Regal
installed the mobile home and removed the wheels and axles. The
wheels and axles were then returned to Regal.
Mr. Coyle has been the president and a stockholder of Regal
since its incorporation in 1983. In addition to preparing
customer purchase orders for Regal, Mr. Coyle has been a salesman
for Regal, and he hired and fired Regal’s employees. During the
years at issue, Mr. Coyle was at the Regal worksite on most
workdays. Mr. Coyle was a majority shareholder with control over
Regal. He acted on behalf of Regal, and Regal acted through him.
Mr. Coyle signed Regal’s Federal income tax returns.
After the sale of a mobile home and the return of the wheels
and axles to Regal, Regal sold them to various purchasers
including Marilyn and Robert Roach (Mr. and Mrs. Roach), who
owned and operated Bob Roach Mobile Home Services, Inc. (Roach
Mobile Home), Jerry Lee Gibson (Mr. Gibson), and Mr. Charles
Vernon Pearce. Roach Mobile Home began purchasing wheels and
axles from Regal in April 1991. Regal sold the wheels and axles
for cash, which is the industry custom. All of Regal’s employees
were authorized to sell the wheels and axles in exchange for cash
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Last modified: May 25, 2011