Medieval Attractions N.V - Page 134

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          ended November 30, 1988, that the commercial paper debt was owed            
          to unrelated parties.  The reports for the audits of MSI for the            
          fiscal years ended July 31, 1989 through 1993, did not reflect              
          that Manver, Gatetown, or the commercial paper companies were               
          related to, or an affiliate of, MSI.                                        
          XV.  IRS Audit                                                              
               Internal Revenue Agent Gary F. Herold (Herold) worked on the           
          Medieval Times examinations from September 1988 until the summer            
          of 1991.  Herold worked with Sans, Parks, Kim, and Melody Blunk             
          on the examinations.  Kim had left C&L and was then employed by             
          the Medieval Times companies.  IRS international examiner Michael           
          Bruton (Bruton) used information provided to him by the Medieval            
          Times representatives to prepare date schedules and                         
          organizational charts.  During the examination, Bruton was not              
          given a signed contract between TM and Gatetown dated March 1,              
          1986, for consideration of $7,312.  Santandreu informed Bruton              
          and Herold that Gatetown and Manver were owned by de Oteyza                 
          (45 percent), Mayol (45 percent), and Santandreu (10 percent).              
          Santandreu provided a document to the IRS that stated that he did           
          not know the shareholders of several corporations, including                
          Dapy, Promidux, Lince, and Manver, because “these are private               
          companies who are doing services for us.”                                   
               Between 1982 and 1991, A. Gelabert, Santandreu, and Segui              
          held positions as officers, directors, attorneys in fact, powers            
          of attorney, or trustees in the listed companies as follows:                




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