- 46 - 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.Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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