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(viz, $31,365,601), (b)(i) the amount of expense reimbursements
CVI owed CV under the export promotion agreement as of that date,
and (ii) accrued State taxes (viz, $228), and (c) an unapplied
balance of $228.
The foregoing transactions were recorded in CVI's general
ledger by entries that were prepared and approved after January
31, 1984, but prior to the time CVI and CV closed their books for
the month of January in accordance with their usual accounting
practice.
For the period January 31, 1982, through January 31, 1984,
no security agreement was executed with respect to the qualified
export receivables sold, nor was any financing statement filed.
Computation of DISC Commission
For each of CVI’s taxable years ending January 31, 1983 and
1984, and December 31, 1984 (taxable years in question),
petitioners computed the commission payable to CVI using the 50
percent of combined taxable income method (50 percent of CTI
method) provided pursuant to section 994(a)(2), allocating a
ratable portion of gross interest expense to qualified export
receipts by product line for purposes of the method.
Stock Warrant Issue
Background
Prior to May 1983, CV decided that, in order to meet its
customers’ needs, it required a new, more advanced computer
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