- 3 - In 1983, Mr. Emert founded and incorporated AEI, and it commenced business. AEI is an S corporation, and Mr. Emert has always been its sole shareholder and corporate officer. AEI sells silicon wafers3 and printed circuit boards (the electronic materials) to high-technology companies. In 1986, Mr. Emert incorporated Distribution. Distribution maintains an inventory of goods.4 Distribution and AEI have never had any written contract describing the business transactions between them. During the years in issue, a typical transaction among AEI, vendors, subcontractors, and customers occurred as follows: Customers contacted AEI for the sale of electronic materials from AEI to the customer.5 The customer executed a purchase order for the purchase of electronic materials, and the customer forwarded the purchase order to AEI. The purchase order identified AEI as the seller and the customer as the buyer. 3 Silicon wafers are thin slices of silicon that are used for making semiconductor devices. 4 In a small number of transactions, Distribution had goods which subcontractors could manufacture into electronic materials for AEI's customers. In these cases, upon AEI's acceptance of a customer's purchase order, AEI purchased the goods for the customer's order from Distribution, AEI shipped the goods to a subcontractor, and the subcontractors used these goods to manufacture electronic materials for AEI's customers. 5 AEI also solicited orders from customers.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011