This applied to Corp-1 salary costs paid by an affiliate in its capacity as common payer on behalf of Corp-1; The same was true for net inter-company payments, which Corp-1 recorded uniformly as liabilities to its related companies. The related companies paid these funds to Corp-1 and not to the taxpayer; and as Corp-1 repaid the advances from its related companies, it made the payments to its related businesses, not to the taxpayer. For a given tax year, CPA — which filed the tax returns of Taxpayer, Corp-1 and associated corporations — would account for Corp-1`s debts to its related companies, as set forth in Corp-1`s books as of December 31, along with Corp-1`s claims on its related companies. . . .