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and the home heating oil business. John and Emma’s family
(Haffner/Fournier family) also owns other entities in addition to
petitioner. The operating entities include petitioner, Haffner’s
Car Care (HCC), and Parker Fuel Corp. (Parker). HCC operates the
car washes and vacuum cleaners located at some of petitioner’s
stations. Parker sells to petitioner, its only customer, all of
the gasoline and home heating oil for resale to consumers. All
three of these operating entities share employees. These labor
cost are paid by petitioner and apportioned among these three
operating entities by way of bookkeeping entries posted in
intercompany accounts.
John and Emma’s family also owns certain nonoperating
entities. The nonoperating entities include Haffner Realty Trust
(Haffner Realty), Fournier Realty Trust (Fournier Realty), and
EMLO Realty Trust (EMLO Realty). Each of these three
nonoperating entities was formed to hold properties transferred
to it by the principals of the three operating entities mentioned
above.
In its early years, petitioner had one class of stock. Four
hundred and fifty shares of that stock were outstanding, and
those shares were owned one-third each by John, Emma, and Louise,
their only child. In 1949, John transferred 76 of his shares to
Louise. Afterwards, Louise owned 226 shares, John owned 74
shares, and Emma owned the remaining 150 shares.
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