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1996 with respect to its taxable year beginning November 9, 1994,
and ending December 31, 1994. This return reflected zero income
and zero expenses.
Navis conducted business throughout 1994. A conference
table, computer supplies and software, business cards, legal
services, fax repair services, and access to an information
service were all purchased by Navis during that year. In
addition, Navis maintained a Federal Express shipping account and
a Sprint telephone service account.
Throughout 1994, petitioner sent and received various
correspondence in his capacity as CEO of Navis. The
correspondence appearing in the record can be summarized as
follows. On January 4, 1994, petitioner sent a letter as CEO of
Navis to Integrated Systems Solutions Corp. of Bethesda,
Maryland, concerning products under development by Navis. On
January 19, 1994, EDS Commercial Services (EDS) sent petitioner a
letter concerning the development of a product known as WorkUSA.
This letter stated in part:
My proposal is that EDS and NAVIS begin a four-month design
effort. During this stage, EDS will establish a core
organization staffed with the expertise necessary to further
define the business processes and requirements, and design
the data base, application systems and technology platform.
* * * we understand the purpose of obtaining these estimates
is to assess EDS’ ability to deliver a full solution, we
also understand that the figures may be used [by] NAVIS in
obtaining financial backing from outside investors. EDS
asks that the source of these estimates be held in
confidence between EDS and NAVIS until such time as NAVIS
and EDS reach an agreement to proceed.
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