BOWMAN, Judge.
Prior to January 1, 1987, the Clevepak Corporation was a business owned and operated in Ohio by Eagle Industries. Pursuant to a plan of reorganization, an agreement was executed on January 31, 1987, whereby Mansfield Plumbing Products, Inc. ("Mansfield Plumbing") and Clevaflex, two separate divisions of Clevepak, became wholly owned subsidiaries of Eagle Industries. By virtue of this agreement, which became effective on February 1, 1987, 87.5 percent...
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