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               Another variable here is that HIC acted as both management              
          entity and parent (individually), so that some of its expenses               
          were related to its activity as a parent company.  In addition,              
          HIC incurred expenses with respect to its involvement with hotels            
          in Brussels and Nice.  Respondent’s experts generally did not                
          recognize the contributions made by HHK and HS, because their                
          efforts were not evidenced by expenditures recorded on those                 
          management subsidiaries’ books.  On those occasions where the                
          efforts of HHK and HS personnel were recognized, respondent’s                
          experts considered them to be performed on HIC’s behalf.  We now             
          consider, in particular, whether any of respondent’s                         
          determinations were arbitrary, capricious, or unreasonable.                  
               1.  Allocations Between HIC and Hyatt Domestic                          
               HIC and Hyatt Domestic entered into a 1974 agreement for the            
          purpose of sharing the services of each other’s sales offices.               
          HIC billed Hyatt Domestic for a contractually agreed level of                
          support from the Hyatt International sales offices.  Hyatt                   
          Domestic included these costs as part of its chain expenses and              
          billed each of its hotels and those of the Hyatt International               
          group for a share of the overall chain expenses.  The chain                  
          allocation formula was based on the number of guest rooms.  In               
          accordance with the 1974 chain services sharing agreement, Hyatt             
          International hotels paid either 50, 75, or 100 percent of a full            
          chain allocation depending on the hotel’s geographical location.             
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