E.J. Harrison and Sons, Inc. - Page 10

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               Well before the audit years, the family formed Rentals,                
          which purchased trucks from petitioner.  Since that time,                   
          petitioner has leased most of its trash hauling trucks from                 
          Rentals.  During the audit years, Rentals was owned 55 percent by           
          Mrs. Harrison and 15 percent each by Myron, James, and Ralph.               
          Loan Guaranties                                                             
               Before the audit years, the California legislature passed a            
          recycling law (known as AB 939) that required California cities             
          to recycle 50 percent of their waste, all of which had previously           
          been dumped into landfills.  In order to comply with AB 939,                
          petitioner was required to supply each of its individual                    
          customers with three barrels instead of one:  A trash barrel, a             
          recycle barrel, and a green waste container for lawn or grass               
          trimmings.  In order to raise the cash needed to purchase the               
          additional barrels and related equipment, petitioner and Rentals            
          arranged for loans from Bank of America.  On June 1, 1992, and on           
          May 3, 1996, Bank of America, as lender, and petitioner and                 
          Rentals, as borrowers, entered into business loan agreements                
          (loan 1 and loan 2, respectively).  Loan 1 provided a $1.5                  
          million line of credit secured by the personal property financed            
          by the loan and was conditioned, in part, on the execution of               
          guaranties by Mrs. Harrison, Myron, James, and Ralph, each in the           
          sum of $1.5 million.  Pursuant to amendments to loan 1 dated                
          August 14, 1992, and June 13, 1994, the line of credit was                  






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