- 29 -
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
Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: May 25, 2011