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the month of January 1984 in accordance with their usual
accounting practice. For accounting purposes, not all of the
sums transferred between CV and CVI were recorded as passing
through the "intercompany account" because the entries used to
record the foregoing transactions were more simplified than those
used to record the corresponding transfers that had occurred in
January 1983.
On January 27, 1984, 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, CV and CVI intended that
CVI would (1) purchase from CV receivables that were outstanding
at the close of business on January 31, 1984, (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
as of that date 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's or CVI's tax and
accounting departments by the close of business on January 31,
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