Inverworld, Inc., et al. - Page 32

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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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