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1984. Additionally, CVI's and CV's tax and accounting
departments did not have available to them on January 31, 1984,
the information necessary to compute the amount of the dividend
CVI intended to pay CV. At the time CVI made the foregoing
transfers to CV, neither CVI nor CV intended that any portion of
the transfers would be repaid to CVI.
By February 15, 1984, CVI's and CV's tax and accounting
departments had received the information necessary to compute the
outstanding balance of qualified export receivables and the
amount of unreimbursed export promotion expenses as of January
31, 1984. On or about February 15, 1984, an agreement entitled
"Purchase of Accounts Receivable Agreement" was executed and
dated as of January 31, 1984. The agreement provided for CVI's
purchases from CV of qualified export receivables having an
aggregate face amount of $33,517,418 at a discount of $2,151,817,
for an aggregate purchase price of $31,365,601. All of the
receivables purchased pursuant to the agreement were qualified
export assets within the meaning of section 993(b).
Also on or about February 15, 1984, an "Action of Directors
in Lieu of a Meeting" was signed by each of CVI's directors in
which it was voted to pay as of January 31, 1984, a dividend of
$5 million to CV. The amount of the dividend is equal to the
difference between (1) the amount of funds CVI wired to CV on
January 27, 1984, (viz, $38,409,795), and (2) the sum of (a) the
aggregate purchase price for the receivables purchased by CVI
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