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agreement transfers substantially all of the accouterments of
ownership. Baird v. Commissioner, 68 T.C. 115, 128 (1977);
Pacific Coast Music Jobbers, Inc. v. Commissioner, 55 T.C. 866,
874 (1971), affd. 457 F.2d 1165 (5th Cir. 1972). In discerning
their intent, we rely on the objective evidence of intent
furnished by the overt acts of the parties to the agreement.
Pacific Coast Music Jobbers, Inc. v. Commissioner, supra; Haggard
v. Commissioner, 24 T.C. 1124, 1129 (1955), affd. 241 F.2d 288
(9th Cir. 1956).
Other factors considered in addition to the passage of title
include, inter alia: (1) How the parties to the agreement treat
the transaction; (2) whether the right of possession is vested in
the purchaser; (3) which party to the agreement bears the risk of
loss with respect to the property; and (4) which party to the
agreement receives the profits from the property. Grodt & McKay
Realty, Inc. v. Commissioner, 77 T.C. 1221, 1237-1238 (1981).
With the foregoing in mind, we consider whether the benefits
and burdens of ownership of the qualified export receivables in
issue passed to CVI by January 31 of each of its relevant taxable
years or at a later time. Although, as noted above, State law
(in this case, Massachusetts law) is not controlling as to the
time at which the sales of qualified export receivables occurred,
we consider Massachusetts law as a factor in our analysis.
Respondent, relying on Mass. Ann. Laws ch. 106, sec. 9-102(b)(1)
(Law. Co-op 1984), contends that the time at a which title passes
is governed by the provisions of Massachusetts law embodying
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