- 19 - GMK's share of the total BKK management cost fee allocation increased by a factor of seven. During that period, facts stipulated by the parties show that GMK's gross receipts increased substantially as well. During that period, there were no unusual events or other requirements of GMK that justified a substantial increase in management services required in 1991 and 1992 as compared to 1990. Additionally, Perrysburg, which allegedly required minimal management services, was charged $29,000 in 1990, $60,415 in 1991, and $42,700 in 1992. Petitioners did not provide any explanation, in terms of services required by Perrysburg from year to year, that would account for those differences. Finally, it defies explanation how Wapak was not allocated any of BKK's management costs in 1990. Petitioners allege that BKK's management costs were allocated using an allocation methodology predicated on the number of hours that the owners spent at or on behalf of each of the commonly controlled corporations. Wapak was incorporated and operating a Taco Bell restaurant in 1990. We suspect that Wapak's insufficient cash- flow was the determinant factor in BKK's management's decision not to allocate Wapak a management cost fee in 1990. Petitioners claim that contemporaneous records of time allocations “were actually created, maintained and used in making the Petitioners’ allocations.” Those records, petitioners claim, were inadvertently destroyed. The only evidence ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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