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1981 through FY 1984 (taxable years at issue) WFGI was engaged in
the acquisition and sale of works of fine art through art
galleries located in New York City, Palm Beach, Chicago, Beverly
Hills and Paris, France. Operations in Paris were conducted in
the form of a French limited liability company, Wally Findlay
Galleries International, S.A.R.L. (French subsidiary), of which
WFGI owned 99 percent and a domestic subsidiary owned the
remaining 1 percent. The French subsidiary commenced operations
in 1971. The French subsidiary performed a number of functions
for the corporate group (Wally Findlay Group). It operated two
Paris art galleries for exhibition and sale of paintings from
WFGI's inventory. The advantages of the Paris location and a
series of highly celebrated exhibitions in the early years served
to enhance WFGI's international reputation. The French
subsidiary also served as the international buying office for the
Wally Findlay Group. The WFGI annual report for the first year
of the French subsidiary's operations explained the benefits
expected from this arrangement:
Working from this office in the midst of the European
art market, our ability to acquire important French
Impressionist and Post-impressionist paintings, a vital
factor in our sales, has been greatly improved. At the
same time, our contacts with contemporary artists have
been expanded. For the first time, we are in a
position to work closely year-round with the European
based artists whom we represent exclusively and to
review new artists. This makes it possible to control
our inventory and to schedule a more far-reaching
program of exhibitions for all our galleries.
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Last modified: May 25, 2011