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its ledgers were part of MANV/MDT’s ledgers during the years in
issue. Petitioner MANV/MDT has not persuaded us that the
payments to RC were business expenses and not dividend payments
to A. Gelabert. Because the payments to RC were not ordinary and
necessary business expenses, as required under section 162, they
were not deductible. Accordingly, respondent’s determination on
this issue will be sustained.
C. A. Gelabert, Santandreu, and Segui
Petitioners argue that Santandreu and Segui were entitled to
compensation because they were directors of MANV and worked on
the expansion of the Medieval Times companies and that
A. Gelabert was entitled to compensation because of the services
he provided to MANV.
Respondent contends that petitioners have a "hat problem"
with regard to the payments to A. Gelabert, Santandreu, and Segui
because it is unclear why MDT made the payments.
We agree with respondent that petitioners have a "hat
problem". Between 1982 and 1991, A. Gelabert, Santandreu, and
Segui held positions as officers, directors, attorneys in fact,
powers of attorney, or trustees in the listed companies as
follows: 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, Lince,
MICV, Manver, MABV, MANV, MTBV, MTNV, Primavert, Protravol,
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