Comtek Expositions, Inc. - Page 56

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               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.                          













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