Ellwest Stereo Theatres of Memphis, Inc., et al. - Page 6

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            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:                                           

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