Computervision International Corp. - Page 4

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          in 1983 and 1984, CVI was a wholly owned subsidiary of CV.                  
          DISC Qualification Issue                                                    
               CVI was organized in 1972 to serve as a sales agent for CV             
          with respect to CV's sales of its products to customers located             
          outside the United States.  CVI qualified as a DISC for each of             
          its taxable years ending prior to the taxable years for which its           
          DISC status is in issue in the instant case (viz, its taxable               
          years ending January 31, 1983 and 1984 (relevant taxable years)).           
          Throughout the periods relevant to the instant case, Martin Allen           
          was CVI's president, Richard Krieger was its treasurer, and James           
          Spindler was its clerk.  They were also the directors of CVI.               
               CV and CVI entered into a series of agreements with respect            
          to their export sales activities.  Under a written agreement                
          entitled "Commission Agreement" (commission agreement) dated as             
          of March 22, 1972, that was in effect during the periods relevant           
          to the instant case, CVI was appointed CV's sales agent with                
          respect to CV's sales of CV's products to customers located                 
          outside the United States.  The commission agreement provided               
          that, in exchange for services provided under the agreement, CVI            
          would receive a commission equal to the maximum amount allowable            
          pursuant to section 994.                                                    
               Pursuant to a written agreement entitled "Agreement                    
          Designating Foreign Marketing Departments and Related                       

          3(...continued)                                                             
          beginning Feb. 1, 1984, and ending Dec. 31, 1984.                           




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