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During 1985, 1986, and through November of 1987, on the
books and records of Nihon Intergraph, of Intergraph, and of
Citibank Tokyo, the principal and interest relating to the
overdraft amount were treated as a yen-denominated debt
obligation of Nihon Intergraph owed to Citibank Tokyo.
On Nihon Intergraph's 1985 and 1986 balance sheets, the
overdraft amount was reflected as a debt obligation of Nihon
Intergraph. The overdraft amount was not reflected as a debt
obligation of Intergraph nor as a capital contribution from
Intergraph to Nihon Intergraph.
For 1985, 1986, and through November of 1987, the overdraft
amount was reported by Nihon Intergraph to Japanese tax and
regulatory authorities as a debt obligation of Nihon Intergraph
to Citibank Tokyo.
For 1985, the overdraft amount was reported by Intergraph on
Form 5471 (Information Return with Respect to a Foreign
Corporation filed with respondent in regard to Nihon Intergraph)
as a debt obligation of Nihon Intergraph.4 The overdraft amount
was not reflected as a debt obligation of Intergraph, nor as a
capital contribution from Intergraph to Nihon Intergraph.
For 1985, 1986, and through November of 1987, with regard to
the overdraft amount, Intergraph reported to its stockholders and
to the U.S. Securities and Exchange Commission (SEC) that
44 Because Nihon Intergraph constituted a foreign corporation,
it did not qualify as part of petitioner's consolidated group for
purposes of filing a consolidated U.S. Federal income tax return.
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Last modified: May 25, 2011