- 78 - Lebasi, N.V. (Lebasi). Linda Parks (Parks) of C&L Orlando prepared and signed the MSI 1988 return. It was also signed by Sans. At the time she prepared the return, Parks was aware of the Form 5472 requirement but did not know that the franchise fee was being paid to a related party. B. MANV/MDT The MANV/MDT Federal tax returns for fiscal years ended November 30, 1987 through 1990, were prepared by the Los Angeles C&L office. Statements attached to the returns indicated that MANV transferred its assets to MABV and that MABV transferred its assets to MDT, in section 351 transactions for stock and securities. The statements included information that MABV had assumed all of the liabilities of MANV. MANV/MDT reported the following on its Federal tax returns: Royalties/ FYE Gross Total Taxable Franchise Nov. 30 Receipts Income Income Payments 1987 $14,409,710 $10,601,670 $4,347,581 $1,441,924 1988 18,665,675 13,836,206 1,183,497 3,719,321 1989 21,278,643 15,537,012 1,054 389 5,148,541 1990 31,251,794 22,688,216 5,563,637 2,975,726 12/31 Calendar Year: 1990 2,367,034 1,730,776 442,963 248,004 1991 34,793,808 24,047,269 2,817,007 4,396,287 Additionally, petitioners MANV/MDT claimed deductions for payments it made as management and consulting fees in the amounts of:Page: Previous 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 Next
Last modified: May 25, 2011