H Group Holding, Inc. and Subsidiaries - Page 4

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                                   FINDINGS OF FACT4                                   
          I.  Historical Background                                                    
               Hyatt Corp. (Hyatt Domestic) is a wholly owned subsidiary of            
          petitioner H Group Holding, Inc. and Subsidiaries (HGH).  HIC is             
          a wholly owned subsidiary of petitioner AIC Holding, Inc. and                
          Subsidiaries (AIC).  All of these entities were organized under              
          the laws of the State of Delaware, and their principal offices at            
          all pertinent times were located in Chicago, Illinois.  The                  
          relevant consolidated corporate Federal income tax returns of HGH            
          and AIC (or their respective predecessors) were timely filed with            
          the Internal Revenue Service Center at Kansas City, Missouri.5               
          For the taxable periods in issue, Hyatt Domestic and HIC were                
          owned or controlled directly or indirectly by the same interests,            
          and said control satisfies the threshold for application of                  
          section 482.6                                                                
               Hyatt Domestic was organized in 1957.  As of 1968, Hyatt                
          Domestic operated seven hotels in the United States with 2,431               
          rooms, collectively.  About one-half of the hotels and rooms were            

               4  The parties’ stipulations of facts and the attached                  
          exhibits are incorporated by this reference.                                 
               5  The issues considered involve petitioners’ subsidiaries,             
          Hyatt Domestic and Hyatt International Inc. (HIC) (and its                   
               6  Attached as an appendix is a diagram reflecting the                  
          relationships of some of the more significant entities addressed             
          in this opinion.                                                             

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