Laidlaw Transportation, Inc. and Subsidiaries - Page 25

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          general account, cash was transferred from the appropriate third            
          tier account to the operating company's fourth tier account.  All           
          fourth tier accounts were zeroed out at the end of the day.                 
          Next, the same thing was done for third and then second tier                
          accounts.  Each second tier account was zeroed out with transfers           
          to or from the first tier master account.  The parties to the               
          CCMP accounted for the transfers between the accounts as                    
          intercompany receivables or payables.  The parties to the CCMP              
          charged what they claim to be interest on all intercompany                  
          payables established under the CCMP.                                        
               In July 1987, LTI, Transit, LWSI, and Tree established a               
          unified CCMP at FNBC.  In 1987 and 1988, LTI's CCMP overdraft               
          limit was between $25 and $30 million for its master                        
          concentration account at FNBC.                                              
               LTL summarized the transfers of money to be made through               
          FNBC's accounts for FNBC officials in Canada.  At the end of each           
          day, LTL or its subsidiaries redeposited enough money in the FNBC           
          CCMP accounts to cover any overdrafts resulting from transfers.             
               LII had a separate CCMP with its subsidiaries.                         
          G.   The Advances at Issue                                                  
               1.   LIL, LIIBV, and LTL                                               
               In the years in issue, LIIBV's primary activity was to                 
          receive funds from LIL and transfer them to petitioners,                    
          generally on the same or next day.  LIIBV advanced funds only to            
          Laidlaw affiliates in the years in issue.  LIIBV's funds came               
          almost exclusively from LIL and from petitioners' payments to               

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