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sales and leases on Norcom’s behalf; and (v) developing Norcom’s
business plans.15
Petitioners established that Quest began to provide services
at least as early as 1991, when Norcom began to reimburse Quest’s
expenses. Moreover, Quest’s services to Norcom increased
substantially in early 1992 after Mr. Lombardi resigned.
The evidence established that numerous senior-level Quest
employees or consultants worked on Norcom matters, including
Messrs. McColl, Espy, Arnold, Wright, and Cross (prior to his
employment at Norcom). Additionally, numerous other Quest
employees provided valuable services to Norcom in support of
these individuals.
The evidence also establishes that Quest provided all of the
services identified in the petition, plus many others. We find
that petitioners have established that services were provided as
claimed in the petition. Throughout the 1990s Quest worked on
Norcom’s financing needs. This includes attempts to find new
15 Petitioners made essentially the same claims in a
position paper provided to respondent during the audit.
Conversely, respondent argues that petitioner must establish that
Norcom was the largest client of Quest and its
predecessor and that the personnel of Quest and its
predecessor spent the majority of their time in
performing services for Norcom.
The Court finds no indication in the record that petitioners made
any such claims to this Court at the time that respondent made
his concession. No such claims were made in the petition.
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