Computervision International Corp. - Page 6

                                        - 6 -                                         
          The agreement also provided that CV would produce, upon demand by           
          CVI, a list of the qualified export receivables in which CVI had            
          an interest, including the identity of the account debtor, the              
          amount of each receivable, and the date on which it arose.  CV              
          was required to bill and collect all payments on the qualified              
          export receivables in which CVI had an interest on CVI's behalf             
          and, unless requested to remit the proceeds to CVI, to substitute           
          an undivided interest in additional receivables for those                   
          discharged.                                                                 
               Using the commissions paid it by CV, CVI, pursuant to the              
          master receivables purchase agreement, periodically purchased at            
          a discount interests in CV's qualified export receivables that              
          were qualified export assets within the meaning of section                  
          993(b).  During its 1981 taxable year, CV entered into the                  
          following sales of qualified export receivables to CVI at a                 
          discount under the master receivables purchase agreement:                   
                Date of Sale            Receivables Face Amount                       
               Oct. 1, 1981             $23,345,288                                   
               Oct. 15, 1981            1,874,000                                     
               Dec. 1, 1981             4,028,369                                     
          Under the terms of the sales, CV was obligated to pay to CVI all            
          proceeds collected with respect to CVI’s interest in the                    
          qualified export receivables on September 30, 1982.                         
               During 1982, CV made an election to use the installment                
          method to report its income with respect to domestic and foreign            
          sales.  Because CV believed that further purchases of qualified             




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