- 82 -                                         
          A. Gelabert--Attractours, Calinvest, Dapy, Holiday, Inverspan,              
          Lince, MTNV, Primavert, Promidux, Roundabout, RC, Spectrust, and            
          Wayout; Santandreu--Amsrott, Attractours, Calinvest, Celin,                 
          Etano, Futureprom, Gatetown, Inverspan, Lebosi, Lince, MICV,                
          Manver, MABV, MANV, MTBV, MTNV, Primavert, Protravol, Roundabout,           
          and Slider; Segui--Calinvest, Futureprom, Holiday, Inverspan,               
          Lince, Manver, MTNV, Primavert, and TM.                                     
               Formal document requests were made to Kim for the MTNV stock           
          and minute books and Manver’s tax returns.  Neither Herold nor              
          Bruton received these documents.  In an October 8, 1990, letter             
          to Bruton, Forsyth stated:                                                  
                    You should also note that to the best of our                      
               knowledge, Manver N.V. has only one minority                           
               shareholder in common with Medieval Times N.V.                         
               Therefore, Medieval Times, N.V. is not in a position to                
               compel Manver N.V. to produce the requested tax                        
               returns.  * * *                                                        
               On June 2, 1992, Greg Cox, an international examiner with              
          the IRS, sent to MDT a notice stating that MDT had been assessed            
          a penalty for not filing certain Forms 5472 as required by                  
          section 6038A(b).  The notice also stated that further penalties            
          would be assessed if the forms were not submitted for                       
          transactions between MDT and MABV, Calinvest, RC, Eurotor,                  
          Manver, and Gatetown.  Kim submitted the forms on behalf of MDT.            
          Some of the forms had disclaimers attached that stated:                     
                    It is our opinion that Medieval Dinner &                          
               Tournament, Inc. and * * * do not meet any of the                      
               definitions defining the boxes in Part II, 3.  By                      
               filing the attached Form 5472, Information Return of a                 
               Foreign Owned Corporation, pursuant to Section 6038A,                  
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