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that CVI's assets as of the close of each year included an open
account of, or loan to, CV, equal to the amount of funds
transferred, which was not a qualified export asset of CVI and
that, therefore, CVI failed to satisfy the 95 percent of assets
test as of the close of each of its relevant taxable years.
We consider whether, for purposes of the 95 percent of
assets test for each of CVI's relevant taxable years, CVI's
assets included qualified accounts receivable purchased from CV
or an open account equal to the amount of funds transferred from
CVI to CV on each of January 31, 1983, and January 27, 1984.
Resolution of that question depends upon whether a completed sale
of the receivables occurred prior to the close of each of CVI's
relevant taxable years.
Petitioners contend that so-called "relaxed ownership
requirements" with respect to the acquisition by a DISC of an
interest in its parent's accounts receivable, such as were
announced by the Commissioner in Rev. Rul. 75-430, 1975-2 C.B.
313, means that arrangements less formal than may be customary
are sufficient to effect the purchase of receivables for purposes
of the 95 percent of assets test. We, however, do not find the
ruling on point because it concerns only the question of whether
a DISC's interest in receivables is sufficient for the
receivables to be considered qualified export assets of the DISC
for purposes of the 95 percent of assets test; it does not
address the time at which a transfer of ownership occurs.
In Derr v. Commissioner, 77 T.C. 708, 723-724 (1981), we set
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