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Petitioner was a shareholder and the president of C&A
Trucking during the years in issue. Petitioner was not involved
in the day-to-day operations of C&A Trucking but did meet with
Stephen Shaw for about 3 hours three times a month to review the
numbers, sign the checks, and review the business volume. C&A
Trucking paid petitioner compensation of $16,180.50 and
$16,221.00 in 1995 and 1996, respectively, for his services
related to C&A Trucking.
C&A Trucking rented gasoline-hauling trailers (Over the Road
Trailers) and a warehouse located in Stillwater from petitioner.
C&A Trucking paid petitioner gross rents of $172,251 and $313,657
in 1995 and 1996, respectively.
Shaw Ltd.
Petitioner was the sole shareholder of Shaw Ltd., which was
an S corporation, during the years in issue. During the years in
issue, Shaw Ltd. was in the business of operating a Dairy Queen
restaurant. In 1995, Shaw Ltd. owned and operated the Western
Sizzlin’ SW restaurant that was later leased to and operated by
Shaw’s Gulf in 1996.
The Dairy Queen restaurant was built and opened for business
in 1994. Shaw Ltd. owned the building and the equipment of the
Dairy Queen restaurant, but the land on which the Dairy Queen
restaurant stood was leased from SDQ LLC. Petitioner was a
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