H Group Holding, Inc. and Subsidiaries - Page 62




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               Revenue Code section 482 and Treasury regulation                        
               section 1.482(d), it is determined that an arm’s-length                 
               charge for management services performed by Hyatt-Hong                  
               Kong, Hyatt-Singapore and Hyatt-Panama equals                           
               $73,200.00 per hotel managed in 1976 through 1978.                      
               * * *                                                                   
          The management fees adjustments generally represent all of the               
          net income of the named subsidiaries in excess of respondent’s               
          determined per-hotel allowance, less the amount already                      
          determined as trade name royalty.  The February 28, 1995, notice             
          for AIC’s 1979 through 1983 taxable years contained the same                 
          explanations for these adjustments as the November 18, 1994,                 
          notice, except that the per-hotel arm’s-length charges determined            
          by respondent were as follows:                                               
                              Year      Amount                                         
                              1979      $75,000                                        
                              1980      87,500                                         
                              1981      100,000                                        
                              1982      62,000                                         
                              1983      62,000                                         
          The number of hotels respondent used to compute the fee                      
          adjustments were as follows:                                                 
                         Year      HHK  HS    HP                                       
                         1976      6    2     1                                        
                         1977      6    2     1                                        
                         1978      7    2     1                                        
                         1979      9    3     1                                        
                         1980      20   3     1                                        
                         1981      28   2     1                                        
                         1982      14   2     1                                        
                         1983      17   2     1                                        







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