DHL Corporation and Subsidiaries - Page 141

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          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 not            




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