- 68 - amount of the funding was $290,000. In 1983 and 1984, DHL made additional equity investments in and loans to NetExpress totaling $3,783,000. In 1985 and 1986, DHL advanced loans to NetExpress in the amounts of $3,107,128 and $6,000,000, respectively. In 1986, those loans were assigned from DHL to DHLI in exchange for an interest-bearing promissory note in the amount of $9,107,128. The transfers of NetExpress stock and loans to DHLI benefited DHL by enabling it to raise cash. When DHL Systems took over the technology functions of MRI in 1989, it was owned 50 percent by DHL and 50 percent by DHLI. As part of this transition, MRI’s technology assets were sold to DHL Systems. The sale price was established by an independent third-party appraisal and was borne by DHL and DHLI in proportion to their ownership of DHL Systems; i.e., 50 percent by DHL and 50 percent by DHLI. X. Respondent’s Determination Before issuance of the notices of deficiency to petitioners, no revenue agent’s report was prepared and no international examiners’ reports were issued to petitioners. An economist’s report was prepared in connection with the examination, but was not provided to petitioners until a Court order compelled its production in pretrial discovery. The pre-notice audit process was protracted and did not operate on a free exchange of information basis. Respondent issued third-party summonses seeking information about petitioners, and petitioners would notPage: Previous 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 Next
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