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l. ASAT, Inc. Intercompany Transactions FY 1991;
m. Interco 1989 & 1990;
n. Form 1120 (1989); and
o. Form 1120 (1990).
All of these documents were in respondent's possession at the
time the notice of deficiency was issued.
Respondent also had the following documents in her
possession when the notice of deficiency was issued:
a. Correspondence between petitioner,
petitioner's counsel, and respondent;
b. notes taken by Ms. Hamilton;
c. initial interview questions and notes of the
initial interview;
d. the Manufacturers' Agents National Association
(MANA) materials;
e. Duns Market Identifier for petitioner dated August
25, 1992; and
f. a copy of petitioner's tax return for the fiscal
year ended April 30, 1992.
C. Information Not Available or Not in Existence
Petitioner did not provide to respondent any budget plans,
work plans, business plans, or other documents showing the
expected income and expenses of petitioner for the years ending
April 30, 1989, through April 30, 1992. Nor did petitioner
provide to respondent any price lists or price guidelines showing
the prices charged by petitioner and/or ASAT, Ltd., to third
parties.
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