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Attached to the letter was a document titled “An Estimate to
NAVIS Communications”, which spelled out in detail the proposal
being offered by EDS to Navis. In May 1994, petitioner prepared
proposals for Goldman Sachs and Sprint concerning products in
development; both of these proposals indicated that they were
from Navis, and both named petitioner as the CEO thereof. On
September 1, 1994, Price Waterhouse, L.L.P., sent a letter to
petitioner as CEO of Navis. This letter stated that “Navis
Communications has asked Price Waterhouse to conduct a market
evaluation study of its new product SEARCHNET, to be launched in
November 1994”, and the letter concluded by stating that “we are
confident that we can successfully help Navis determine the
market penetration and initial marketing program required for a
successful launch of SEARCHNET.” Throughout 1994, Navis also
entered into a variety of confidentiality and nondisclosure
agreements with a number of individuals and business entities.
There is no evidence in the record indicating that a tax return
was filed for Navis with respect to 1994 or any other taxable
year.
Petitioner gained a business advantage from the
incorporation of Navis insofar as the corporation gave petitioner
“a more legitimate base, versus Dale Sundby the sole proprietor”
in his business dealings.
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Last modified: May 25, 2011