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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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