- 6 - petitioners were engaged in the adult entertainment business during the taxable years at issue. A.J. Films, Ellwest Stereo Theatres of Fort Worth, Ellwest Stereo Theatres of Phoenix, Ellwest Stereo Theatres of Youngstown, Jolar Cinema, and Premium Films no longer conduct business. During the taxable years at issue, all petitioners were owned, in whole or part, by Harry V. Mohney (Mohney), either directly or indirectly as one of several beneficiaries of a trust. Mohney directly owned 100 percent of the stock of Corporate Investments. Mohney and his children owned beneficial interests in the Durand Trusts, a group of five domestic trusts, which owned all the stock of Michigan Reef Development Corp. The Durand Trusts also owned all the stock of Dynamic Industries Ltd., a domestic corporation of which M.I.C. Limited was the wholly owned subsidiary. Mohney together with three family members and a business associate named Elizabeth Scribner (Scribner) were the beneficiaries of the Amaranta Trust, a foreign trust that owned all the stock of several foreign holding companies. All remaining petitioners were first- or second-tier wholly owned subsidiaries of two of these foreign holding companies: Fun Films, Ltd., located in the Turks and Caicos Islands, and Caribbean Films, N.V., whose residence for Federal income tax purposes was the Netherlands Antilles. Among the foreign corporations existing under the Amaranta Trust umbrella were also two others of significance to these cases:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011