Medieval Attractions N.V - Page 82

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          agreements.  A list of the documents that were in existence in              
          Kissimmee during 1983 referred to the January 24, 1983, contract.           
          V.  Coopers & Lybrand Planning and Petitioners' Documentation               
               Coopers & Lybrand (C&L) is a “big six” accounting firm known           
          for its worldwide market.  C&L prepared all of the tax returns              
          for the Medieval Times companies beginning with the MTNV return             
          in 1982.                                                                    
               In 1985, Santandreu sought the assistance of C&L in                    
          Brussels, Belgium, to find a structure that could be used for the           
          nontaxable receipt of payments made to the Spanish investors by             
          MTNV.  C&L suggested the use of a nonresident United Kingdom                
          company to Santandreu in a letter dated August 6, 1985.                     
               Gatetown Limited (Gatetown) was a United Kingdom corporation           
          registered on or about May 1, 1985, by Nigel Leonard Blood.  In             
          March 1986, Segui’s father-in-law, Jose Garcia de Oteyza Romero             
          (de Oteyza), was in contact with Harris, Lippman & Co. (Harris),            
          an accounting firm in the United Kingdom.  In an April 1986                 
          letter, de Oteyza sent funds to Harris to acquire Gatetown.  The            
          letter stated that “Gatetown Limited will take care of getting              
          paid Royalties and copyrights of a Dinner-Show situated in the              
          U.S.A.”  The correspondence also referred to a company called               
          Protravol Limited (Protravol) that would be used for the “buying            
          and selling from Spain to U.S.A. of souvenirs”.  The letter                 
          informed Harris that the directors of both companies should be de           






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