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issue.2
Some facts have been stipulated and are so found. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference. We need find few facts in addition to
those stipulated and shall not, therefore, separately set forth
our findings of fact. We shall make additional findings of fact
as we proceed.
Background
All petitioners except for James A. and Dorothy A. Patterson
resided in Kentucky at the time they filed their respective
petitions. The Pattersons resided in Florida at the time they
filed their petition.
The Huffman Group
The Huffman group of corporations (Huffman group) consists
of four members (sometimes, the members): Neil Huffman Nissan,
Inc. (Nissan); Neil Huffman Volkswagen, Inc. (Volkswagen); Neil
Huffman Enterprises, Inc., d.b.a. Neil Huffman Dodge (Dodge); and
Neil Huffman, Inc., d.b.a. Huffman Chrysler Plymouth (Chrysler).
The members sell new and used automobiles in Kentucky. At least
one of each married pair of petitioners owns stock in one or more
of the members. Each of the members has elected to be treated as
an S corporation under the provisions of section 1361.
2 Hereafter, all section references are to the Internal
Revenue Code of 1986, as amended and in effect for the years in
issue.
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