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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
subsidiaries).
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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