Medieval Attractions N.V - Page 147

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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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