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company, is a corporation that was organized pursuant to the laws
of the Cayman Islands on November 27, 1981.
INC is a corporation that was organized pursuant to the laws
of the State of Delaware on December 22, 1982. At the time the
petitions in docket Nos. 27089-90 and 3441-93 were filed, INC's
principal office was at 1250 N.E. Loop 410, Suite 1030, San
Antonio, Texas 78209. During the years in issue, LTD owned,
either directly or indirectly, all of the outstanding stock of
INC. On November 15, 1985, INC was registered with the SEC as an
investment adviser pursuant to section 203 of the Investment
Advisers Act of 1940.
Holdings is a corporation that was organized pursuant to the
laws of the State of Delaware on February 24, 1987. At the time
the petition in docket No. 3442-93 was filed, Holdings' principal
office was at 1250 N.E. Loop 410, Suite 1030, San Antonio, Texas
78209. During certain of the taxable years in issue, LTD owned
all the outstanding stock of Holdings, and Holdings was the owner
of all of the outstanding stock of INC.
B. Petitioners' Returns
LTD maintained its books and records using a June 30 taxable
year. LTD did not file U.S. Annual Withholding Tax Returns for
U.S. Source Income of Foreign Persons (Forms 1042) for calendar
years 1984, 1985, 1986, 1987, 1988, and 1989; U.S. Corporation
Income Tax Returns of a Foreign Person (Forms 1120F) for its
taxable years ended June 30, 1987, 1988, and 1989; or any other
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