Lee F. Haney, Sr., and Jean C. Haney, a.k.a. Jeanie Haney - Page 3




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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated into our findings by this reference.                 
          Petitioners are married and resided in Oklahoma at the time that            
          they filed their petition.                                                  
               Petitioner Lee F. Haney, Sr. (petitioner), is the sole                 
          shareholder of Flair Enterprises, Inc. (Flair Enterprises or the            
          company), an S corporation.  Flair Enterprises operates three               
          full-service automobile paint and body shops doing business as              
          Flair Body Works in the Oklahoma City metropolitan area.  The               
          Flair Body Works shops are managed by petitioners’ sons, Phillip            
          Haney and Alan Haney.                                                       
               During the years in issue, it was the business practice of             
          Flair Enterprises to keep complete and accurate records of work             
          performed by Flair Body Works for their insurance customers.                
          Flair Body Works is a preferred provider for several major                  
          automobile insurance companies, which requires strict records to            
          be maintained by service providers seeking payment on claims.               
          During the years in issue, Flair Enterprises maintained two                 
          separate sets of books for Flair Body Works.  One set of books              
          recorded transactions that were covered by the automobile                   
          insurance companies; the other recorded transactions with                   
          noninsurance customers and other regular payors.                            








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