H Group Holding, Inc. and Subsidiaries - Page 60




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                                        Trade name                                     
                    Taxable year        adjustment                                     
                    Jan. 31, 1980       $2,159,000                                     
                    Jan. 31, 1981       3,266,000                                      
                    Jan. 31, 1982       4,603,000                                      
                    Jan. 31, 1983       5,279,000                                      
                    Jan. 31, 1984       5,548,000                                      
                    Jan. 31, 1985       6,070,000                                      
                    Jan. 31, 1986       5,735,687                                      
                    Jan. 31, 1987       5,935,143                                      
                    Jan. 31, 1988       7,333,495                                      
                         Total     45,929,325                                          
          The October 12, 1990, notice of deficiency contained the                     
          following explanation for the 1983 through 1985 tax years:                   
               It has been determined that an adjustment be made in                    
               accordance with the provisions of Internal Revenue Code                 
               Section 482 and the regulations thereinafter to                         
               increase your income for the value of the trade name                    
               “Hyatt”.  Accordingly, your taxable income for year                     
               ended January 31, 1983; January 31, 1984 and January                    
               31, 1985 have been increased in the amounts of                          
               $5,279,000; $5,548,000 and $6,070,000 respectively.                     
          The Explanation of Items in the October 28, 1991, notice of                  
          deficiency for HGH’s taxable years 1980 through 1982 states:                 
               Hyatt Corporation (HC) engaged in transactions with                     
               Hyatt International Corporation (HIC), relating to                      
               HIC’s use of “Hyatt” trade names, trademarks, and other                 
               intangible assets, which were not at arm’s-length                       
               terms.  Pursuant to section 482 of the Internal Revenue                 
               Code and Treas. Reg. �1.482-2(d), it is determined that                 
               an arm’s-length royalty or license fee for these                        
               transactions equals 1.5% of the gross revenues of each                  
               hotel operated under the “Hyatt” name by HIC or any of                  
               its subsidiaries.  * * *                                                
          The January 27, 1993, notice of deficiency for HGH’s 1986 through            
          1988 tax years contained the same above-quoted explanation.                  







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