Payless Cashways, Inc. and Its Subsidiaries - Page 4

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          at Two Pershing Square, 2300 Main Street, Kansas City, Missouri             
          (Two Pershing Square), since October 1986.                                  
               Payless is a full-line building materials supplier serving             
          the home improvement, maintenance, and repair market.  Payless’             
          customers include both “do-it-yourself” customers and                       
          professional contractors such as remodelers, residential                    
          builders, and other similar businesses that purchase large                  
          quantities of building materials.  In the year in issue, Payless            
          operated 181 stores in 23 States and had 13,685 employees.                  
               Payless’ sales for 1986 were $1,525,648,000.  During 1986,             
          Payless purchased merchandise from approximately 3,000 different            
          suppliers.  Payless purchased some of its merchandise, including            
          home improvement products, equipment, supplies, and materials               
          from foreign manufacturers and vendors.  Beginning in 1981,                 
          Payless purchased merchandise from foreign sources through its              
          import department with the assistance of various purchasing                 
          agents.  None of the purchasing agents utilized by Payless were             
          employees of Payless.  Beginning in 1985, Payless purchased                 
          merchandise from foreign sources through Multi-Growth, Ltd., a              
          limited liability company organized under the laws of Hong Kong.3           
          In 1986, Payless’ cost of merchandise sold was $1,041,678,000.              
          In 1986, Payless purchased merchandise from foreign manufacturers           

               3The record does not disclose any ownership interest held by           
          Payless in Multi-Growth, Ltd., and petitioner did not assert any            
          such interest on brief.                                                     

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