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itself out as the owner or purchaser of the employees'
residences.2
For regular sales during the years in issue, the average
length of time between acceptance of the RSC's offer and passage
of title to the third-party purchaser was as follows:
Holding Period
Year Days
1983 102
1984 159
1985 186
1986 147
For assigned sales during the years in issue, the average length
of time between assignment of the third-party contract to the RSC
and passage of title to the third-party purchaser was as follows:
Holding Period
Year Days
1983 44
1984 44
1985 44
1986 54
During the years in issue, gross proceeds from sales of
residences to third parties in regular and assigned sales were as
follows:
2 Respondent offers a single document, a letter written by
petitioner's relocation administrator to a mortgage company, to
support the contention that petitioner holds itself out as the
purchaser of employee residences. The letter identifies
petitioner as purchasing an employee's home and paying the
employee his equity in the residence. However, petitioner did
not normally write letters of this type and typically referred
inquiries by mortgage lenders to the relocation service company
(RSC). We give little weight to the letter as no other evidence
indicates that petitioner held itself out to third parties as the
owner of the residences.
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