Medieval Attractions N.V - Page 146

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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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