Amdahl Corporation and Consolidated Subsidiaries - Page 4

                                        - 4 -                                         
          various forms of home disposal assistance to relocating employees           
          for the past 20 years.  Petitioner's competitors in the computer            
          mainframe business provide similar home disposal services to                
          their employees.                                                            
               Petitioner's employee relocation program is part of its                
          human resource department and is administered by a relocation               
          administrator under the supervision of a relocation manager.  The           
          relocation administrator provides information to relocating                 
          employees about available relocation benefits, including the home           
          disposal assistance.  The relocation administrator and manager              
          also arrange for shipment of household goods, temporary lodging,            
          and car rental, and reimburse employees for their moving                    
              To assist employees in the sale of their homes, petitioner             
          contracts with unrelated relocation service companies.  Pursuant            
          to petitioner's contract with a relocation service company (RSC),           
          the RSC offers to purchase the residences of eligible relocating            
          employees and resell the residences to third parties.  Petitioner           
          compensates the RSC for all costs incurred in assisting                     
          relocating employees in the sale of their homes and also pays the           
          RSC a fee for its services.  At various times during the years in           
          issue, petitioner used either Transamerica Relocation Service,              
          Inc. (Transamerica), VanRelco, Inc. (VanRelco), or Intergroup               
          Management Co. and its successor, Associates Intergroup                     
          Management Co. (each, Intergroup) as its RSC.  Generally,                   

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011