- 4 - 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.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