- 83 -                                         
          section 482 determinations, petitioners must show an abuse of                
          respondent's discretion.21                                                   
          V.  Arm’s-Length Consideration                                               
               A.  Respondent’s Allocations of Management Fee Revenue for              
          HHK, HS, and HIC                                                             
               HHK and HS received management fee revenue from hotels for              
          which HHK or HS did not provide services.  In this regard,                   
          petitioners acknowledge that HIC was responsible for European and            
          Central American hotels throughout the years in issue (1976                  
          through 1983).  Accordingly, we sustain respondent’s allocation              
          of income for these hotels to HIC.22                                         
               HHK received consulting fees and royalties from HESA without            
          performing services for HESA or the Mexican hotels.  HESA managed            
          the hotels in Mexico and earned the management fees, and the                 
          consulting agreement was merely a mechanism to reduce local                  
               21 In the final analysis, it did not make a difference that             
          petitioner was unable to show that all of respondent's                       
          determinations were arbitrary, capricious, or unreasonable.  That            
          is so because, in those instances where we redetermined an arm’s-            
          length consideration, petitioners were not able to meet the                  
          lesser standard of showing that their reporting or trial position            
          was for an arm’s-length consideration.                                       
               22  BVS recommended allocation of revenue from certain                  
          hotels in the Middle East and North Africa.  These particular                
          hotels were not in operation during the years affecting the                  
          allocations to HIC (1976 through 1983), and allocation in the                
          later years that involve only Hyatt Domestic’s allocations                   
          (through 1988) would not change the result because, ultimately,              
          the royalties were computed as a percentage of gross hotel                   
          revenues rather than being based on HIC’s revenues.  Thus, it is             
          not necessary to analyze the particulars of hotels managed in                
          those regions.                                                               
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