Amdahl Corporation and Consolidated Subsidiaries - Page 22

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               The real benefit that petitioner received was the transfer             
          of employees to locations as required by its computer business.             
          The transactions were structured to encourage employees to accept           
          petitioner's offer to transfer.  The contracts of sale gave                 
          petitioner a means to provide relocating employees their equity             
          in their residences before the residences were sold.  This                  
          enabled relocating employees to purchase new residences with a              
          minimum of delay.  The contracts also relieved relocating                   
          employees of the duplicate burden of paying the costs of a                  
          mortgage, property tax, and other costs of home ownership for               
          both their new and former residences.  However, relocating                  
          employees were still legally responsible for the mortgage and tax           
          expenses of their former residences.  Payments on the mortgages             
          or for other expenses relating to property ownership were for the           
          benefit of relocating employees and not for petitioner to acquire           
          an equity interest in the residences.  The purported sales were             
          nothing more than a way for an employer to subsidize the costs of           
          its employees' transfers.                                                   
               As part of the relocation program, petitioner protected its            
          relocating employees from the risk of loss on the sale of their             
          residences.  The equity payments were not contingent on the sale            
          of the residences to third parties, and petitioner assumed the              
          risk of loss on the sale.  Although petitioner assumed certain              
          risks of loss in connection with its employees' residences, in              
          substance, we find that petitioner was reimbursing the costs of             




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