Amdahl Corporation and Consolidated Subsidiaries - Page 5

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          petitioner's contracts with Transamerica, VanRelco, and                     
          Intergroup provide for substantially similar home disposal                  
               When petitioner extends a relocation offer to an employee,             
          petitioner informs the employee of its relocation benefits and              
          gives the employee a brochure describing the relocation                     
          assistance that petitioner offers.  The brochure provides that              
          petitioner will assist in the sale of the employee's home with              
          the aid of a "third-party agent".  If an employee who is eligible           
          for home disposal assistance agrees to a proposed transfer,                 
          petitioner notifies the RSC to offer to purchase the employee's             
          home in accordance with petitioner's contract with the RSC.  An             
          employee's eligibility for home disposal assistance depends on              
          criteria defined in petitioner's corporate policies and                     
          procedures.  Petitioner does not take into consideration whether            
          residences will appreciate in value in deciding to provide home             
          disposal assistance to relocating employees.  Petitioner has not            
          based its decision to provide relocation assistance on whether              
          employee residences will appreciate in order to offset the costs            
          to petitioner for relocation.                                               
               In addition, the RSC does not have discretion over whether             
          to purchase a particular employee's residence.  The RSC must                
          offer to purchase an employee's residence if the residence                  
          satisfies certain requirements set forth in petitioner's contract           
          with the RSC.  Eligible employees are not required to accept the            

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Last modified: May 25, 2011