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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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