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expenses that it incurred regarding the EVC's. Petitioner did
not charge either NUF or OPL for providing the point of contact
with shippers who declared excess value and paid EVC's. No
interest on excess value amounts that had been collected before
the excess value amounts were transferred to NUF was paid to NUF.
During 1984, if a shipper did not pay a bill that included excess
value amounts, petitioner attempted to collect the entire amount
due from the shipper, including any EVC's included in the bill.
Petitioner did not reduce the amount transferred to NUF by any
amount uncollected or any cost it incurred in collecting
delinquent EVC's. Petitioner also adjusted and paid all claims
with respect to lost or damaged shipments. Petitioner also
defended against shippers' claims that had been denied.
Petitioner did not reduce the amounts it transferred to NUF in
order to compensate itself for performing these activities and
did not otherwise charge NUF or OPL for performing any of these
activities.
Petitioner also continued to provide other services related
to EVC's. Petitioner provided "controlled parcel handling"
procedures, which were expensive and time consuming. Those
procedures included bagging, tagging, and tracking high value
packages that had declared values in excess of $100. Petitioner
maintained a loss prevention department in which it employed
personnel to audit controlled parcel handling procedures. Such
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