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Petitioner’s compensation from Luttrell was $34,718.30 and
$34,872.00 for 1995 and 1996, respectively.
Shaw’s Gulf also leased and operated four other convenience
stores in which petitioner held no direct nor indirect ownership
interest in the property.
Barden Kellum (Kellum), vice president of operations,
managed the day-to-day operations of Shaw’s Gulf and its
affiliates and was responsible for the maintenance of the
properties leased by Shaw’s Gulf. Kellum consulted with
petitioner either by telephone or in person approximately 3 to
5 hours a week.
Shaw’s Gulf also leased a house located in Stillwater from
R&S. Petitioner contributed the house to R&S sometime prior to
the years in issue. Kellum was not responsible for any of the
residential rentals because petitioner hired an agency to manage
the residential rentals.
C&A Trucking
C&A Trucking was a subsidiary of Shaw’s Gulf. C&A Trucking
was in the transportation business; on a call-and-carry basis, it
delivered petroleum products. About 25 to 35 percent of C&A
Trucking’s business was from Shaw’s Gulf. Stephen Shaw, general
manager of C&A Trucking, managed the day-to-day business
operations, dispatch, and billing.
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