Pan American Foods, Inc. - Page 2

                                        - 2 -                                         
                     Taxable Year Ending      Deficiency                              
                        June 30, 1988         $576,964                                
                        June 30, 1989         632,046                                 
                        June 30, 1990         511,793                                 
                        June 30, 1991         81,389                                  
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After settlement, the issue for decision is whether certain            
          funds transferred to entities related to petitioner constitute              
          ordinary and necessary business expenses under section 162(a).              

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          When the petition was filed, petitioner’s principal place of                
          business was located in Houston, Texas.                                     
               During the years in issue, petitioner operated as the                  
          exclusive U.S. corporate distributor for Gamesa, S.A. de C.V.               
          (Gamesa), a Mexican manufacturer of food products, such as                  
          cookies, crackers, bakery goods, and pasta.                                 
               In 1984, a Mexican businessman named Alberto Santos de Hoyos           
          (Santos de Hoyos) formed petitioner as a Texas corporation and as           
          a wholly owned subsidiary of Cremin Corp., B.V. (Cremin), a newly           
          formed Netherlands corporation.  Cremin in turn was a wholly                
          owned subsidiary of Rubbik Corp., N.V. (Rubbik), a newly formed             
          Netherlands Antilles corporation.                                           




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