Medieval Attractions N.V - Page 29

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          v. Commissioner, T.C. Memo. 1994-201, affd. without published               
          opinion 86 F.3d 1162 (9th Cir. 1996), we found that the                     
          taxpayer's transactions lacked economic substance and stated:               
                    The various transfers among entities controlled or                
               owned by * * * [the taxpayer] are reminiscent of those                 
               with which we have previously dealt.  See, e.g., Karme                 
               v. Commissioner, 73 T.C. 1163, 1171, 1173-1174 (1980)                  
               affd. 673 F.2d 1062 (9th Cir. 1990); Bail Bonds by                     
               Marvin Nelson, Inc. v. Commissioner, T.C. Memo. 1986-                  
               23, affd. 820 F.2d 1543 (9th Cir. 1987); see also                      
               Schiavenza v. United States, 52 AFTR2d 83-6364, 85-1                   
               USTC par. 9155 (N.D. Cal. 1984).  In those cases, the                  
               taxpayers used foreign and domestic entities to make                   
               prearranged "money movement[s]" within the "system" of                 
               entities.  Karme v. Commissioner, supra at 1169.  The                  
               funds involved in those money movements never left the                 
               system of controlled entities.  Typical of the                         
               transactions in those cases were key documents that                    
               "were not executed, and sometimes not even written in                  
               final form, until long after their purported dates",                   
               id. at 1191, loans and transfers that were made between                
               system entities to negate risk of loss; lenders that                   
               were "continu[ing] to enjoy the use" of funds supplied                 
               to other entities, id. at 1193; and back-to-back                       
               transfers of funds made within hours of each other all                 
               resulting in no net outlay of money by any single                      
               entity or person.  See Bail Bonds by Marvin Nelson,                    
               Inc. v. Commissioner, supra.  As in those cases, "It is                
               apparent that * * * [taxpayer's] transactions * * *                    
               'did not appreciably affect [his] beneficial interest                  
               except to reduce [his] tax'."  Bail Bonds by Marvin                    
               Nelson, Inc. v. Commissioner, supra (citing Knetsch v.                 
               United States, 364 U.S. 361, 366 (1960), quoting                       
               Gilbert v. Commissioner, 248 F.2d 399, 411 (2d Cir.                    
               1957)).                                                                
          Here, too, the transfers are "reminiscent" of those with                    
          which we have previously dealt.  Domestic and foreign entities              
          were used to make prearranged money movements within the system             
          of entities controlled by the Spanish investors.  In December               
          1987, the J. Montaner-controlled companies, primarily Dapy, and             
          the Santandreu-controlled companies, primarily Roundabout,                  



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