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Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. The
evidence from 30 days of trial included 6,368 pages of transcript
and thousands of exhibits, many of which contained multiple parts
and/or were duplicates of other exhibits. The failure of the
parties to engage in timely, good faith, voluntary and orderly
exchange of documents resulted in the necessity of 39 separately
filed stipulations through the course of the trial, without
logical or consistent sequence or organization. It is not
reasonable to reproduce here all of the findings requested by the
parties. Many of them are exaggerated extrapolations or
unrealistic interpretations of the evidence. We have set forth
only those findings that are necessary to explain and dispose of
the issues for decision in these cases. Detailed findings
concerning certain documents are necessary because of disputes as
to the sham or fraudulent nature of petitioners' transactions.
Documents and facts at times subsequent to the years in issue are
set forth because they are relevant in determining when or
whether other documents were prepared or events occurred. The
other agreed facts are incorporated in our findings by this
reference.
FINDINGS OF FACT
Petitioner Medieval Show, Inc. (MSI), is a corporation
organized under the laws of Florida with its principal place of
business in Kissimmee, Florida. Petitioner Medieval Dinner &
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