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"intercompany account".
On January 31, 1983, and prior to the application of the
above-described payment by CVI to CV, CV held qualified export
receivables as described in the master receivables purchase
agreement and CVI was indebted to CV (1) pursuant to the export
promotion agreement for expenses that previously had been paid by
CV but had not yet been reimbursed by CVI and (2) for accrued
State taxes that would be paid by CV in the first instance. At
the time CVI wired the payment to CV, both CV and CVI intended
that CVI would (1) purchase from CV the receivables of CV that
were outstanding at the close of business on January 31, 1983,
(2) reimburse CV for the aforementioned expenses, (3) pay CV an
amount equal to the accrued State taxes, and (4) pay a dividend
to CV from a portion of the transferred funds.
All events necessary to determine the total amount of the
receivables, expenses, and taxes had taken place by the close of
business on that date; however, the information necessary to
compute the total amount of the items was not available to CV and
CVI's tax and accounting departments on that date. In prior
years, CVI regularly had reimbursed CV for export promotion
expenses pursuant to the export promotion agreement and for State
tax payments. Additionally, CVI's and CV's tax and accounting
departments did not have available to them on January 31, 1983,
the information necessary to compute the amount of the dividend
CVI intended to pay CV. At the time CVI made the foregoing
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