Comtek Expositions, Inc. - Page 12

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          petitioner.  The royalty agreement says nothing about fees to be            
          collected by Crocus.  After December 31, 1994, trade show                   
          exhibitors located outside the former Soviet Union either paid              
          their exhibition fees by check in U.S. currency payable to                  
          petitioner or by wire transfer in U.S. currency to a bank account           
          in the name of ECI, while exhibitors located in the former Soviet           
          Union continued to pay their exhibition fees to Crocus.  During             
          the taxable periods at issue, i.e., January 1, 1995 through July            
          31, 1996, 90 percent of the fees for exhibition space at foreign            
          trade shows were paid by exhibitors located outside the former              
          Soviet Union, and the remaining 10 percent were paid by                     
          exhibitors located in the former Soviet Union.7                             
               Second, under Article 4.1 of the royalty agreement, ECI                
          agrees to pay petitioner a royalty of 25 percent of gross                   
          revenues of foreign trade shows, while under Article 4.2 of the             
          royalty agreement, petitioner agrees to pay ECI a royalty of 35             
          percent of gross revenues from trade shows in the United States             
          conducted after March 1, 1995.  Petitioner reported 25 percent of           
          gross revenues from foreign trade shows in accordance with                  
          Article 4.1., except in cases where the foreign trade show was              
          conducted solely by petitioner.  Petitioner reported 100 percent            
          of gross revenues from trade shows in the United States conducted           


               7The parties have not stipulated the relevant percentages              
          for foreign trade shows conducted before Jan. 1, 1995.                      





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