Swallows Holding, Ltd. - Page 8

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               Aurora Elsa Arnaiz (Arnaiz) is the sister of Rosas.  She is            
          a citizen and resident of Mexico.  On June 1, 1992, petitioner              
          issued additional shares of its stock to Arnaiz.  Afterwards,               
          Arnaiz owned 52 percent of petitioner’s stock, and Rosas owned              
          the remaining 48 percent.                                                   
          III.  Petitioner’s Initial Tax Return                                       
               On September 14, 1992, petitioner filed a Form 1120-F with             
          respondent’s service center in Philadelphia, Pennsylvania                   
          (Philadelphia Service Center), for its short taxable year from              
          June 27, 1991, through May 31, 1992 (1992 taxable year).  The               
          return (petitioner’s initial return) was petitioner’s first                 
          Federal income tax return.  That return was prepared by Francisco           
          A.F. Cervantes (Cervantes), petitioner’s tax adviser and                    
          certified public accountant in California.  As to petitioner’s              
          1992 taxable year, petitioner’s initial return reported that                
          petitioner had no income or expense, that it had not engaged in a           
          trade or business in the United States, and that it had no                  
          effectively connected income.  Petitioner’s initial return also             
          reported that petitioner’s business activity was real estate and            
          that its product or service was investment.  Petitioner’s initial           
          return also reported that petitioner was incorporated in Barbados           
          and that petitioner was subject to income tax under the laws of             
          Barbados.                                                                   







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