- 83 - Medieval Dinner & Tournament, Inc. is not admitting that * * * was a “related party” of Medieval Dinner & Tournament, Inc. during the period * * * under Sections 6038, 6038A or any applicable Section, law or code; and Medieval Dinner & Tournament, Inc. is not admitting that there exist any “reportable transactions” between Medieval Dinner & Tournament, Inc. and * * * for the period * * * under Sections 6038, 6038A or any applicable Section, law or code. There were disclaimers for transactions with RC, Eurotor, Manver, and Gatetown. OPINION With the exception of the additions to tax and penalties for fraud, petitioners have the burden of proving that respondent’s determinations as made in the notice of deficiency are erroneous. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Rockwell v. Commissioner, 512 F.2d 882, 886 (9th Cir. 1975), affg. T.C. Memo. 1972-133. I. Management and Consulting Fees Petitioners MANV/MDT and MSI claimed deductions for payments made for management and consulting fees in the following amounts: 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 MSI 1988 1989 Eurotor $232,549 $86,341 With the exception of a portion of MANV/MDT’s 1987, 1988, and 1989 payments to Eurotor, respondent determined that the abovePage: Previous 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 Next
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