- 20 -                                                    
                  Northwest recorded as income on its books the amount of                                  
            petitioner's bad debt writeoff.  After June 30, 1989, petitioner                               
            did not receive any other assets, cash, or property owned or on                                
            the books of Northwest as of June 30, 1989.  Funds that                                        
            petitioner received from Northwest after June 30, 1989, were                                   
            attributable to units delivered to Northwest after June 30, 1989.                              
            Foretravel Incentive Program for Dealerships                                                   
                  Petitioner established uniform bookkeeping systems for the                               
            subsidiaries, and the subsidiaries also used standard paperwork,                               
            including forms distributed by the Recreational Vehicle Dealer                                 
            International Association.  The dealerships were retail merchants                              
            that sold and serviced new motor homes, including those                                        
            manufactured by Foretravel, less expensive motor homes, used                                   
            motor homes, trailers, and other service recreational vehicles.                                
            Each dealership carried at least one "X" brand line of motor                                   
            homes.                                                                                         
                  Motor home manufacturers use a variety of incentive plans                                
            designed to promote the sale of their products.  Petitioner was                                
            no exception.  Through its incentive program, petitioner sought                                
            to maintain a steady flow of coaches through its manufacturing                                 
            operation, thus avoiding fluctuations in employment, supplies,                                 
            and general level of operation.  Petitioner also sought to obtain                              
            positive publicity from its customers, maintain customer                                       
            goodwill, alleviate cash-flow problems, and maintain its                                       
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