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It may fairly be inferred from the stipulated record that
petitioner requested Crocus’s services because Crocus had the
expertise and support staff necessary to conduct trade shows in
the former Soviet Union. The services provided by Crocus were
necessary to operate the foreign trade shows. Crocus was also
responsible for relations with exhibitors located in the former
Soviet Union, including collecting fees from such exhibitors. It
may fairly be inferred that one purpose of the foreign trade
shows was to increase mutual contacts and provide networking
opportunities for exhibitors located outside the former Soviet
Union to establish business relationships with companies in the
former Soviet Union. Although fees collected from exhibitors
located in the former Soviet Union accounted for only 10 percent
of all trade show receipts, the attendance of such exhibitors at
foreign trade shows no doubt increased networking opportunities
for exhibitors located outside the former Soviet Union, thereby
making the trade shows more attractive to them.
Because services provided by Crocus were essential to
conduct and increase the profitability of the foreign trade
shows, it may fairly be inferred that petitioner or ECI made
arrangements for Crocus to receive some payment for its services
in addition to the reimbursement of its direct expenses of
operating the foreign trade shows.25
25It might be objected that Crocus’s right to compensation
(continued...)
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