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in Europe, the Middle East, and Latin America. Mister Donut
joined in the filing of petitioner's consolidated returns.
Hereinafter, we will generally refer to Mister Donut's
transactions as petitioner's, since Mister Donut was petitioner's
wholly owned subsidiary.
Petitioner's Asian and Pacific Mister Donut Operations
As of January 1989, petitioner had registered Mister Donut
trademarks in the following countries: Indonesia, the
Philippines, Taiwan, Thailand, Australia, the People's Republic
of China, Hong Kong, Malaysia, New Zealand, Singapore, and South
Korea.
Petitioner, as franchisor, had entered into Mister Donut
franchise agreements in Indonesia, the Philippines, Thailand, and
Taiwan2 (the operating countries). The franchise agreements in
effect on January 31, 1989, were as follows:
Date of
Initial No. of Mister
Agreement Territory Franchisee Donut Shops
Apr. 30, 1987 Indonesia PT Naga Puspita 2
Bujana
Nov. 16, 1981 Philippines Naque Franchising Co. 49
Mar. 16, 1984 Taiwan Continental Foods 6
May 19, 1978 Thailand Thai Franchising Co. 21
2Although styled a Technical Cooperation Agreement,
petitioner's agreement in Taiwan was, in all material respects,
the same as its franchise agreements.
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Last modified: May 25, 2011