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MANV/MDT 1987 1988 1989
Eurotor $271,041 $373,854 $ 37,546
RC 132,937 380,096 228,128
A. Gelabert 16,580 17,215 21,877
Santandreu 37,000 21,069 8,000
Segui 44,000
Included in the 1987 through 1990 returns were additional
deductions for royalties/franchise fees and interest expenses.
The 1988 and 1990 returns also claimed deductions for guarantee
fees.
For fiscal years ended 1986 through 1991, MANV/MDT’s taxable
income totaled $15,738,227. During the same period, payments to
Manver for franchise/royalties fees totaled $18,336,335. Of the
preroyalty payment profits, 46 percent went to MANV/MDT and
54 percent went to Manver.
No Forms 5472 were filed by MANV/MDT on its 1986 through
1991 income tax returns for transactions with Manver, Gatetown,
Lince, Futureprom, Attractours, Edemle, Celin, Amsrott, Slider,
Protravol, Etano, or Lebasi. Forsyth reviewed and signed the
Federal returns for 1986 through 1989. Forsyth believed that
Manver and MDT were related, but Onate informed him in August
1987 that Manver and MDT were not related. On August 11, 1989,
Forsyth signed the MDT Federal income tax return for the fiscal
year ended November 30, 1988, which was filed without Forms 5472.
August 11, 1989, was less than 2 weeks after the November 30,
1988, MDT certified audit report was issued that disclosed that
Manver was a related party.
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