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income. Petitioner did not include excess value amounts billed
to regular shippers in its filings with the SEC and the ICC for
the year ended December 31, 1984. Otherwise, petitioner's
activities with respect to the excess value activity basically
remained the same as in prior years. Petitioner continued to
bill customers for shipping charges on the basis of information
recorded by shippers on the package pickup records. The bills
reflected all amounts to be collected from shippers, including
EVC's. All amounts collected, including EVC's, from the shippers
were deposited in petitioner's bank accounts. Petitioner
continued to process all claims for loss or damage to parcels,
including any excess value portions of the claims. If a claim
for loss or damage was paid, petitioner continued to remit the
amount for the claim by check to the shipper.
Petitioner did not apply for, and did not hold, an insurance
license of any type. During 1984, petitioner's employees who
processed shippers' claims were not licensed as claims adjusters
in the States in which they processed claims. NUF did not
participate in the resolution of specific claims in 1984,
challenge the amounts of specific loss claims paid by petitioner,
or challenge the amounts of loss and damage claims that
petitioner subtracted from the amounts that it remitted to NUF
during 1984 in connection with NUF contract IMB 9310977.
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