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On October 28, 1983, LTL formed Travelways, Inc.
(Travelways), a Delaware holding and operating corporation.
Before September 1, 1987, Travelways owned all of Transit, a
holding and operating corporation formed under California law on
June 26, 1961, and all of LTI's passenger services subsidiaries.
On September 1, 1987, Laidlaw Transit, Inc., changed its
name to Laidlaw Transit (West) Inc. (LTW). On November 5, 1987,
Travelways changed its name to Laidlaw Transit, Inc. (Transit).8
After the name changes, most of the Laidlaw U.S. east coast
passenger services subsidiaries were merged into Transit, and
most of the Laidlaw U.S. west coast passenger services
subsidiaries were merged into LTW.
During the years in issue, Transit and its subsidiaries
provided passenger and school bus services in the United States.
LTL and its subsidiaries were the largest provider of school
transportation services in North America.
2. LII and Its Subsidiaries
a. LII
LTL formed LII (a petitioner in these cases) on March 24,
1981, as the holding company for LTL's U.S. and Canadian solid
waste services operations. LII is a Delaware corporation and an
accrual basis taxpayer. Before 1982, LTI owned 80 percent of the
8 Unless otherwise indicated, references to "Transit"
include references to Travelways, Laidlaw Transit, Inc., Laidlaw
Transit (West), Inc., and Transit.
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