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In addition to the real estate that Shaw’s Gulf leased from
petitioner, Shaw’s Gulf also leased properties from entities in
which petitioner held an ownership interest. During the years in
issue, Shaw’s Gulf operated Texaco Food Mart #5, a gas station
and convenience store, that was leased from RS&M Properties II
(RS&M). Petitioner was a 55-percent partner and the designated
tax matters partner of RS&M during the years in issue.
Shaw’s Gulf leased Buy N Bye #10, a convenience store, from
R&S Partnership (R&S). Petitioner was a 50-percent partner of
R&S during the years in issue, and petitioner contributed the
Bye N Bye #10 convenience store to R&S sometime prior to the
years in issue.
In 1996, Shaw’s Gulf leased the Western Sizzlin’ restaurant
located in Stillwater (Western Sizzlin’ SW) from S.C. Shaw, Ltd.
(Shaw Ltd.), an S corporation of which petitioner was the sole
shareholder.
Shaw’s Gulf operated a convenience store at a truck stop
located in Billings, Oklahoma, that was owned by Luttrell Oil
Company (Luttrell). Petitioner was a shareholder and president
of Luttrell during the years in issue. He reviewed the financial
statements and tax bills of Luttrell, but he did not have much
involvement in the day-to-day operations of Luttrell.
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