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returns. Brookfield Development filed a final Federal partner-
ship return for Partnership that indicated that Partnership
terminated on February 28, 1992. At the time of its termination,
Partnership had a net worth of less than $7 million and no
employees.
At the time PFI filed the petition in this case, it had a
net worth of less than $7 million and fewer than 500 employees.
At all relevant times including the date on which the
petition in this case was filed, petitioner was wholly owned by
Pacific Harbor Capital Inc. (Pacific Harbor) which, in turn, was
wholly owned by PacificCorp Financial Services (PacificCorp
Financial), and PacificCorp Financial was wholly owned by
InnerPacific (now known and herein referred to as Pacific Hold-
ing) which, in turn, was wholly owned by PacificCorp. At those
times, Pacific Harbor, PacificCorp Financial, Pacific Holding,
and PacificCorp each had a net worth in excess of $7 million.
Bills for the legal services and expenses at issue in
litigating this case were addressed to Pacific Harbor. Bills for
the services and expenses at issue of the experts who testified
on behalf of PFI at the trial of this case were addressed to
PacificCorp Financial. Pacific Harbor paid all of the amounts
billed for legal and expert services and expenses in connection
with this case. (These amounts shall collectively be referred to
as the litigation costs at issue.)
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Last modified: May 25, 2011