- 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
expenses.
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