mr. robin beran, you wore mr. perkins i believe -- what was your role in 1999? >> i was and then the head of the tax department. >> okay. and you work directly under the csarl transaction? >> i was involved with this formulation. yes. the implementation. people did much more work and i. >> so you were involved in the formulation? >> would you look at seven please? this is the way in which he w.c. recommended that caterpillar could reduce its taxes. it is one page for the document. here is what it says. purpose, read characterize marketing company in come. we characterize marketing company in come to achieve u.s. tax deferral. and then if you look further down as you point out it was caterpillar -- as you said, ms. legacy, taken out of the chain as an unnecessary middleman. we will get to that in the minister just tell unnecessary it was. the direct purchase wind in geneva promise suppliers is that correct so far? >> yes, sir. >> mr. perkins, is that correct? >> estimated. >> was it the caterpillar tax department that came up with the idea to remove caterpillar,

>> i do not. >> do you know, mr. beran? >> the number of parts -- >> approximately. within 100 million or so. warehoused in the united states. would you know, mr. perkins? >> no, i do not. >> how about within half a billion. >> i would say in total, i believe we have just under a million serviceable replacement parts. i do not know how many of those are stocked in the united states. >> would it surprise you to know that there's about a billion and a half parts no -- not types of parts but parts warehoused in the united states? >> i don't know that number. >> okay. it wasn't -- wouldn't surprise you or would surprise you. >> individual, so not part numbers but just individual numbers of parts? i frankly have no idea how many there might be housed in the you'd. >> okay. >> would you take a look, please, at exhibit 53. >> i don't have an exhibit 53 in my book. thank you. >> do you have it now? >> yes. >> okay. this is the value of -- i want to talk to you about the value of what was transferred to csarl as part of the license. and this is a pwc document that addresses th

mr. robin beran, you wore mr. perkins i believe -- what was your role in 1999? >> i was and then the head of the tax department. >> okay. and you work directly under the csarl transaction? >> i was involved with this formulation. yes. the implementation. people did much more work and i. >> so you were involved in the formulation? >> would you look at seven please? this is the way in which he w.c. recommended that caterpillar could reduce its taxes. it is one page for the document. here is what it says. purpose, read characterize marketing company in come. we characterize marketing company in come to achieve u.s. tax deferral. and then if you look further down as you point out it was caterpillar -- as you said, ms. legacy, taken out of the chain as an unnecessary middleman. we will get to that in the minister just tell unnecessary it was. the direct purchase wind in geneva promise suppliers is that correct so far? >> yes, sir. >> mr. perkins, is that correct? >> estimated. >> was it the caterpillar tax department that came up with the idea to remove caterpillar,

beran tax director rodney perkins senior tax manager? >> yes among the interaction. >> my first round of time is over. >> thank you mr. chairman. mr. quinn on the earlier panel i was asking the professors the basic relation how does the irs contract with a large multinational corporation i would like to expand that not only to a large corporation like caterpillar but also to large accounting firm like yourselves? can you describe how the irisin treks during -- interacts during the tax year? >> the iras during the entire year is a continued audit as you describe very and maintain it continuous presence on site and actively engage with caterpillar personnel directly in to the extent that we don't have direct interaction with the irs only through caterpillar and one invited in by caterpillar to

mr. williams report to you? >> yes. >> mentioned some of the key contacts at caterpillar and among them i'm asking you where they robin beran tax director rodney perkins senior tax manager? >> yes among the interaction. >> my first round of time is over. >> thank you mr. chairman. mr. quinn on the earlier panel i was asking the professors the basic relation how does the irs contract with a large multinational corporation i would like to expand that not only to a large corporation like caterpillar but also to large accounting firm like yourselves? can you describe how the irisin treks during -- interacts during the tax year? >> the iras during the entire year is a continued audit as you describe very and maintain it continuous presence on site and actively engage with caterpillar personnel directly in to the extent that we don't have direct interaction with the irs only through caterpillar and one invited in by caterpillar to assist them in those matters. >> was there any consulting done as you are working with caterpillar to comply with a the law to lower their tax burden? was there any contact by the irs at that time? >> i