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disposition of relocating employees' residences. Reimbursed
costs include expenses for: appraisal and inspection, repair and
maintenance, improvements, utilities, insurance, property taxes,
homeowner association fees, mortgage payments, other expenses
directly attributable to specific residences, interest charged on
direct and indirect expenses, gain or loss on the sale to third
parties, broker commissions, and other closing costs. In
addition, petitioner pays the RSC a fee of 1.25 percent of the
appraised value of the residences in regular sales, and either .5
percent (Intergroup) or 1 percent (Transamerica and VanRelco) of
the appraised value in assigned sales. The RSC bears no risk of
loss in connection with the sale of the residences.
During the years in issue, petitioner provided home disposal
assistance to at least 188 employees, 176 of which are in issue.
Approximately 74 percent of the home sales in issue were regular
sales, and 26 percent were assigned sales. Petitioner did not
intend to acquire legal title to the residences. It viewed the
costs associated with assisting relocating employees in the sale
of their residences as an expense of conducting its computer
business and did not intend to profit from the sale of the
residences to third parties. Petitioner was primarily concerned
with inducing employees to relocate and ensuring that the
residences were sold quickly. Petitioner generally does not hold
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Last modified: May 25, 2011