Intergraph Corporation and Subsidiaries - Page 10

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            debt owed by Nihon Intergraph to Intergraph and a reduction to                                
            zero of Nihon Intergraph's third-party loan payable account                                   
            (reflecting the fact that the overdraft amount had been paid                                  
            off).  Nihon Intergraph’s capital account continued to reflect                                
            only Intergraph’s initial capital contribution of �100 million.                               
                  On Intergraph’s 1987 yearend financial statement,                                       
            Intergraph, in effect, was treated as subrogated to Citibank                                  
            Tokyo’s creditor rights with regard to the overdraft amount, and                              
            Intergraph’s transfer of the �823,943,385 into Nihon Intergraph's                             
            checking account to eliminate the overdraft amount was reflected                              
            as an intercompany loan from Intergraph to Nihon Intergraph.                                  
                  In March of 1988, on Nihon Intergraph’s balance sheet                                   
            attached to Intergraph's 1987 Form 5471 filed with respondent                                 
            with respect to Nihon Intergraph, Nihon Intergraph’s intercompany                             
            debt to Intergraph in the amount of �823,943,385 ($6,484,169) was                             
            reflected as paid off, and Intergraph's capital investment in                                 
            Nihon Intergraph was reflected as increased by the same amount.                               
                  For Japanese reporting purposes for 1987, Nihon Intergraph’s                            
            financial statements continued to reflect that Intergraph's                                   
            payment of the overdraft amount gave rise to an intercompany debt                             
            to Intergraph.                                                                                
                  On petitioner's 1987 consolidated Federal income tax return,                            
            however, petitioner treated the overdraft amount as a loan by                                 
            Citibank Tokyo to Intergraph, not as a loan to Nihon Intergraph,                              
            and petitioner treated Intergraph's transfer of the �823,943,385                              




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