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driver-employees to approximately 100 trucking company clients.8
By the end of taxable year 1996, TLC was leasing driver-employees
to approximately 300 trucking company clients. Although most of
TLC’s trucking company clients were located in Minnesota,
Montana, or Pennsylvania, by the end of taxable year 1996 TLC had
trucking company clients in 31 states. As of the time of trial
in this case, TLC leased a total of 5,563 driver-employees to a
total of 453 trucking company clients.
TLC’s trucking company clients were engaged principally in
the over-the-road trucking industry. As of the beginning of
taxable year 1993, approximately 90 percent of TLC’s trucking
company clients were over-the-road carriers, while the remaining
10 percent were local carriers. By the end of taxable year 1996,
approximately 65 percent of TLC’s trucking company clients were
over-the-road carriers, and 35 percent were local carriers.
In an attempt to attract clients, TLC’s sale representatives
used a variety of sales techniques, including (1) newspaper
advertisements, (2) face-to-face meetings with, and other presen-
tations to, trucking company owners, (3) brochures, (4) form
letters, and (5) other promotional mailings. Two of the bro-
chures that TLC provided to prospective clients were entitled
“The Fact Book” (Fact Book) and “Your Trucks/Our Drivers” (Your
8The number of truck drivers that each trucking company
client leased from TLC ranged from 1 to 50.
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