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Petitioner is a closely held corporation. Warren Hunt, Jr.,
and his wife, Anita Hunt, own 48 percent of the stock of
petitioner; Randall Dean Hunt and his wife, Cynthia Hunt, own 26
percent of the stock of petitioner; Warren Hunt III and his wife,
Rosemarie Hunt, own 26 percent of the stock of petitioner.
Randall Dean Hunt and Warren Hunt III are the sons of Warren
Hunt, Jr., and Anita Hunt.
Petitioner paid Federal corporate income taxes of $256,863
for 1996 and $350,456 for 1997. For each of 1996 and 1997,
petitioner paid total dividends of $24,000.
Petitioner’s shareholders, through revocable living trusts,
own the raw land underlying all the cardlocks operated by
petitioner.2 Petitioner leases the raw land from its
shareholders’ revocable living trusts through ground leases.
Petitioner owns the improvements and operates the cardlock
businesses.
The operation of a cardlock business, which requires the use
of underground storage tanks and pipes, entails a high degree of
financial risk because of the potential for leaks, which can
cause soil and groundwater contamination that can be very
2The Watt Avenue, Mother Lode Drive, and Fee Drive land is
owned by the Warren N. Hunt III and Rosemarie A. Hunt Revocable
Living Trust and the Randall Dean Hunt and Cynthia Lynne Hunt
Revocable Living Trust. The Mosquito Road, Roseville Road, and
White Rock Road land is owned by the Warren N. Hunt, Jr., and
Anita M. Hunt Revocable Living Trust.
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Last modified: May 25, 2011