- 104 - Petitioners’ expert conceded that the services of IPS were integral in that those services were provided to unrelated parties, although petitioner’s expert also concluded that IPS’ activities were minimal during the years in issue. It appears that IPS was uniquely capable of providing its services since the design manuals and area programs, although tailored to suit a particular hotel, were intended to exemplify how a Hyatt International hotel should be constructed or operated. No other design company would have access to this information. Thus, we find the activities of IPS are integral. Other services, including marketing and coordination of insurance and benefits were performed and may be integral, but there is no way to distinguish the costs of the other services provided to HHK and HS from the total costs to the Hyatt International group entities. The subsidiaries or the hotel owners paid the direct costs; however, the indirect costs (i.e., overhead) were not included. Thus, whether we conclude that such services were or were not integral, we are effectively unable to determine the 31(...continued) in the operations of the recipient. (iv) Services are an integral part of the business activity of a member of a controlled group where the recipient has received the benefit of a substantial amount of services from one or more related parties during its taxable year. * * *Page: Previous 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 Next
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