- 49 -                                         
          These numbers were described in the explanation of items as                  
          “counts any hotels actually managed by” the respective entity;               
          i.e., HHK, HS, or HP.                                                        
                                       OPINION                                         
          I.  Preliminary Matters--Evidentiary Objections                              
               A.  Documents Executed During or Pertaining to Taxable Years            
          Subsequent to Those in Issue                                                 
               Respondent objected, on the grounds of relevance, to the                
          admission into evidence of certain documents executed during                 
          and/or pertaining to periods subsequent to the taxable years in              
          issue.  Alternatively, respondent objected on the grounds that               
          any probative value of such documents is outweighed by prejudice             
          or considerations of undue delay, waste of time, or the needless             
          presentation of cumulative evidence.  The documents in question              
          primarily include management agreements and financial statements             
          of Hyatt International hotels.                                               
               Respondent’s objections, in essence, bear more heavily on               
          the probative weight of the documents than on their                          
          admissibility.  It is noted that respondent did not object to                
          documents concerning subsequent periods when the documents                   
          supported or were helpful to respondent’s expert’s opinion.                  
               Respondent relies on rules 401, 402, and 403 of the Federal             
          Rules of Evidence.  Under the circumstances here, we hold that               
          the documents to which respondent objected are relevant and                  
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