- 13 - US West Grants to Gallup; and (9) MFS Anaheim. The third-party customer contracts for these nine conduit installation projects constitute long-term contracts as defined by section 460(f). 2. IRU Projects By November 1995, Qwest was in negotiations with WorldCom Network Services, Inc. (WorldCom), for rights to use a limited number of fibers in fiberoptic cable installed along particular routes. On February 26, 1996, Qwest granted WorldCom an IRU in 24 dark fibers over three routes: (1) WorldCom Dallas-Houston; (2) WorldCom Denver-El Paso; and (3) WorldCom Santa Clara-SLC. Pursuant to the IRU agreement, Qwest pulled fiber for the three IRU projects, as described above. In addition to pulling fiber for WorldCom, Qwest also pulled fiber for its own potential future use or sale. Instead of pulling 24-fiber fiberoptic cables, Qwest pulled cables with a larger number of fibers. While WorldCom had an IRU in 24 of the fibers, Qwest retained control over the remaining fibers in the same cable. The IRU agreement constitutes a long-term contract as defined by section 460(f). For tax purposes, Qwest’s granting of the IRUs to WorldCom was treated as a sale of those fibers. The total contract price for the IRU agreement was $65,196,466.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011