- 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 NextLast modified: May 25, 2011