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UNITED STATES v. ASSOCIATES COMMERCIAL CORP.

No. 82 C 1451.

548 F.Supp. 171 (1982)

UNITED STATES of America, Plaintiff, v. ASSOCIATES COMMERCIAL CORPORATION, formerly known as Associates Capital, Inc., Defendant.

United States District Court, N. D. Illinois, E. D.

September 30, 1982.

Attorney(s) appearing for the Case

James K. Wilkens, Trial Atty., Tax Div., Dept. of Justice, Washington, D. C., for plaintiff.

Mark J. Lieberman, Chicago, Ill., Eugene I. Meyers, Vice President & Senior Tax Counsel, Steven J. Gombinski, Gulf & Western Inds., New York City, of counsel, for defendant.

MEMORANDUM OPINION

WILL, District Judge.

I. BACKGROUND FACTS

In 1972, defendant, Associates Capital Corporation (hereinafter "Associates"), first began advancing money to Dot Engravers, Inc. (hereinafter "Dot") pursuant to a continuing accounts receivable financing agreement. Under that arrangement Associates advanced Dot cash equal to a fixed percentage of the face amount of Dot's accounts receivables, taking in return such receivables as collateral...

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