HURST v. COMMISSIONER

Docket No. 15792-02.

124 T.C. 16 (2005)

124 T.C. No. 2

RICHARD E. AND MARY ANN HURST, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 3, 2005.


Attorney(s) appearing for the Case

Terry L. Zabel, for petitioners.

Bryan E. Sladek, for respondent.


HOLMES, Judge:

Richard Hurst founded and owned Hurst Mechanical, Inc. (HMI), a thriving small business in Michigan that repairs and maintains heating, ventilating, and air conditioning (HVAC) systems. He bought, with his wife Mary Ann, a much smaller HVAC company called RHI; and together they also own the building where HMI has its headquarters.

When the Hursts decided to retire in 1997, they sold RHI to HMI, sold HMI to a trio of new owners who included...

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