(1988)], another decision involving Sajac in the role of an unrelated third party and transferee, die Tax Court examined the four-factor test set forth in Paccar.
Several tax cases have focused upon the transfer of excess inventory by Volvo Cars of North America (formerly known as Volvo North America Corporation) to Sajac Corporation.
Although the original contract in 1980 transferred title to the inventory from Volvo to Sajac upon its delivery, the contract also contained several provisions that allowed Volvo to retain control over the inventory after its transfer.
In order to remedy certain terms in the 1980 contract, Volvo signed a new sales agreement with Sajac in 1983; this agreement transferred all rights and ownership interests in the excess inventory to Sajac.
The second question required the jury to determine whether the inventory transfers from Volvo to Sajac after the 1983 contact's execution date constituted bona fide sales.
The district court rejected the government's motion with regard to the inventory transfers that took place after the 1983 contract's execution date; however, the court granted the government's motion with regard to the inventory transfers by Volvo to Sajac prior to that execution date.
* The method by which Sajac maintained its inventory of all excess parts transferred to it by Volvo remained the same (and Sajac made no distinction between the inventory transfers before and after the 1983 contract).