United Parcel Service of America - Page 73




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          audits took place at petitioner's hub and delivery center                   
          operations.  Petitioner's special controlled parcel handling                
          procedure with respect to high-value packages constituted extra             
          services for shipments whose declared value exceeded $100.                  
          Petitioner did not reduce the amount transferred to NUF in return           
          for performing the controlled parcel handling procedures and did            
          not otherwise charge NUF or OPL for performing these activities.            
               Before January 1, 1984, petitioner performed all the                   
          functions and activities related to the EVC's and was liable for            
          the damage or loss of packages up to their declared value.  After           
          January 1, 1984, petitioner continued to perform all the                    
          functions and activities related to EVC's, including billing for            
          and receiving EVC's, and remained liable to shippers whose                  
          shipments were damaged or lost while in petitioner's possession.            
          Petitioner continued to receive shippers' claims for lost or                
          damaged goods, investigate and adjust such claims, and pay such             
          claims out of the EVC revenue that it had collected from                    
          shippers.  The difference between petitioner's EVC activity                 
          before and after January 1, 1984, was that after that date it               
          remitted the excess of EVC revenues over claims paid, i.e., gross           
          profit, to NUF, which, after subtracting relatively small                   
          fronting fees and expenses, paid the remainder to OPL, which was            
          essentially owned by petitioner's shareholders.                             







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