Pulsar Components International, Inc. - Page 3

                                        - 3 -                                         

               Some of the facts have been stipulated and are so found.               
          The stipulations and attached exhibits are incorporated herein by           
          this reference.  Petitioner's principal office was in Hicksville,           
          New York, when it petitioned the Court.  Petitioner filed its               
          Federal income tax return based on a fiscal year ending July 31,            
          1985, and it used the cash receipts and disbursements method.               
          1.  Petitioner                                                              
               Petitioner is a "third-tier chip broker” that locates,                 
          purchases, and sells computer chips, electronic components, and             
          integrated circuits.2  Petitioner and its predecessor, Pulsar               
          Components, Inc. (Components), developed a niche in their field             
          that enabled them to take advantage of supply and demand                    
          imbalances caused by the production capacities of microchip                 
          manufacturers and the production needs of computer manufacturers.           
          Petitioner located scarce parts during periods of low supply and            
          high demand by using a network of brokers, surplus houses,                  
          distributors, and manufacturers, of which it had a working                  

          2 Computer manufacturers obtain electronic components and                   
          microchips from three sources (tiers) of supply.  The first tier,           
          the primary source of supply of electronic components, is a chip            
          manufacturer such as Intel, Micron, or Fujitsu.  Approximately              
          90 percent of the parts purchased by equipment manufacturers are            
          purchased directly from chip manufacturers.  The second tier,               
          franchise distributors such as Arrow Electronics, Hamilton-Avnet,           
          and Schweber, are typically large corporations that warehouse               
          substantial inventories of parts.  Franchised distributors have             
          franchise agreements to represent product lines of certain                  
          manufacturers, and they sell parts out of inventory for a set               
          markup that is usually 15 to 20 percent.  The third tier consists           
          of chip brokers and traders like petitioner.                                




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011