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Roundabout, and Slider; and Segui--Calinvest, Futureprom,
Holiday, Inverspan, Lince, Manver, MTNV, Primavert, and TM. The
individuals were working in several different capacities
concurrently, and it is unclear in which capacity they were
working at any particular time. Additionally, the individuals
were also shareholders in many entities. Santandreu and Segui
were shareholders in MANV and Eurotor. A. Gelabert was a
shareholder in MANV. If they were acting in their capacity as
shareholders, the services they provided to protect their
interests as shareholders are not deductible under section 162.
Olton Feed Yard, Inc. v. United States, supra. We conclude that
the amounts paid to A. Gelabert were wages, and the amounts paid
to Santandreu and Segui were dividends for the following reasons.
A. Gelabert was hired to run the castle. He was in charge
of renovating the castle and getting the operation off the
ground. He was entitled to payment for his services as an
employee of MANV. The amounts paid to A. Gelabert were not
dividends because, as we have previously concluded, he was
receiving his dividends through RC.
Eurotor was entitled to receive compensation for the
management services it provided to petitioners. In order to
provide those services, it had to have representatives working
with petitioners. Santandreu and Segui spent considerable time
in the United States assisting with operations and providing
management services. We conclude that Santandreu and Segui were
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