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years in issue. Micca purchased real property and, with
financing provided by Amoco, built a gasoline station and
convenience store on that property. Micca operated the gasoline
station from 1996 until sometime in 1998. Micca filed a
corporate income tax return for 1996 and reported taxable income
of $52,923 for that year.
H. Tomson, Inc.
In August 1995, Tomson, Inc. (Tomson), was organized as a
Florida corporation. Messrs. Gowni and Mansour owned and
operated Tomson. In 1995, Tomson negotiated the purchase from
Amoco of an existing Amoco gasoline station that was located in
Orlando. The purchase price of the gasoline station was
$330,000. Tomson was to pay Amoco $140,000 at closing. Tomson
borrowed $140,000 from Citicorp North America, Inc., in order to
make this payment. The remaining $190,000 of the purchase price
was secured by a note owed to Amoco. The note was payable over
10 years and was reduced by 1 cent for every gallon of motor fuel
that Tomson purchased from Amoco. The closing date for the sale
was January 22, 1996.
Tomson contracted with Orange Petroleum, Inc. (Orange
Petroleum), for the installation of gasoline tanks and related
work. Tomson paid Orange Petroleum $159,462 for this work, which
was completed by April 22, 1996.
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