- 148 -
expenditures of $1,020 ($1,052 deductions less $32 for
capitalized organizational expenses). Thus, during 1983, Zeus
had $860,832 in liquid assets ($696,623 + $165,229 - $1,020).
On March 25, 1983, Zeus repaid the $51,000 loan outstanding
from IRA. On October 21, 1983, Zeus transferred $774,000 to IRA
in exchange for a $774,000 receivable from Holding Co. During
1983, Zeus transferred $28,000 to IRA in exchange for $28,000 of
receivables from Holding Co.26 Thus, during 1983, Zeus
transferred a total of $853,000 in cash to IRA in repayment of a
loan and in exchange for Holding Co. receivables.
IRA's 1983 consolidated return reported that Zeus' assets at
the end of the year included cash of $7,832, loans receivable of
$866,000, partnership interests with a negative value of $20,875,
and other assets (capitalized organizational expenses) of $32.
From 1979 through 1983, Zeus apparently invested a net of
$163,685 in partnerships.27
26
On December 5, 1983, Zeus transferred $13,000 to IRA in
exchange for a $13,000 receivable from Holding Co. IRA's general
ledger shows that in 1983 Holding Co.'s subsidiary Zion acquired
from IRA a $15,000 receivable due from Holding Co. for $15,000.
The 1984 general ledger shows that Zeus' loans receivable of
$866,000 included $802,000 owed by Holding Co. and $64,000 owed
by HELO. The record does not disclose how Zeus acquired the
remaining receivable of $15,000 from Holding Co.
27
Based on IRA's consolidated returns, Zeus contributed to
unidentified partnerships $100,000 in 1979 and $127,372 in 1980
and received a return of capital of $63,696 in 1981 and $1 in
1982 (probably due to rounding of numbers) computed as follows:
(continued...)
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