- 56 - The result of our holdings is that petitioner is entitled to deduct 30.6 percent and 33.8 percent, respectively, of the stipulated net profits of the foreign trade shows for the 7 months ended July 31, 1995, and the fiscal year ended July 31, 1996, as compensation to Crocus. In summary, we hold that petitioner and Crocus were not engaged in a joint venture during the taxable periods at issue; petitioner must therefore report all revenues from foreign trade shows collected by petitioner or ECI during the taxable periods at issue. Petitioner may deduct its direct expenses, the Expocentr rent expenses, and Crocus’s reimbursed direct expenses, all in accordance with the stipulation of the parties. Petitioner is also entitled to deduct the amount of fees collected by Crocus during the taxable periods at issue from exhibitors located in the former Soviet Union as reasonable compensation to Crocus for its services in operating the foreign trade shows. To give effect to the foregoing, Decision will be entered under Rule 155.Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56
Last modified: May 25, 2011