- 2 - Taxable Year Ending Deficiency June 30, 1988 $576,964 June 30, 1989 632,046 June 30, 1990 511,793 June 30, 1991 81,389 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After settlement, the issue for decision is whether certain funds transferred to entities related to petitioner constitute ordinary and necessary business expenses under section 162(a). FINDINGS OF FACT Some of the facts have been stipulated and are so found. When the petition was filed, petitioner’s principal place of business was located in Houston, Texas. During the years in issue, petitioner operated as the exclusive U.S. corporate distributor for Gamesa, S.A. de C.V. (Gamesa), a Mexican manufacturer of food products, such as cookies, crackers, bakery goods, and pasta. In 1984, a Mexican businessman named Alberto Santos de Hoyos (Santos de Hoyos) formed petitioner as a Texas corporation and as a wholly owned subsidiary of Cremin Corp., B.V. (Cremin), a newly formed Netherlands corporation. Cremin in turn was a wholly owned subsidiary of Rubbik Corp., N.V. (Rubbik), a newly formed Netherlands Antilles corporation.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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