Medieval Attractions N.V - Page 136

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               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 above              




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