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for $7,312; Manver’s purchase of the Medieval Times concept from
Gatetown on May 27, 1986, for $5.6 million; MSI’s right under the
Manver license to use the Medieval Times concept from Manver for
$7 million on December 22, 1987, and the related commercial paper
used to finance the transaction; and MDT’s right under the Manver
license to use the Medieval Times concept from Manver for
$15.75 million on December 22, 1987, and the related commercial
paper used to finance the transaction.
XIII. Federal Tax Returns
A. MTNV/MSI
The MTNV Federal tax returns for fiscal years ended July 30,
1987, and August 1987 (partial year return), and the MSI returns
for the fiscal years ended July 31, 1988, and July 31, 1989, were
prepared by the C&L Orlando office. Statements attached to the
returns indicated that MTNV transferred its assets to MTBV and
that MTBV transferred its assets to MSI, in section 351
transactions for stock and securities. The statements reported
that all future operations would be reported by MSI. The
statements reflected the property received, stock and securities
issued, and liabilities assumed: “Medieval Times B.V. has
assumed all of the liabilities of Medieval Times, N.V.”
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