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4. Flow of Payments by the Five 1985 Through 1989
After IRA transferred money from the Five to Carlco, TMT,
and BWK in 1984, the structure in which payments were received
from the Five changed. The payments from Essex and Hyatt
(through KWJ Partnership) were no longer reported as IRA's
income. Carlco, TMT, and BWK became partners of the Essex
partnership and formed the KWJ Co. partnership. Hyatt payments
were reported as income of KWJ Co. partnership. Accordingly, the
payments from the Essex and KWJ Co. partnerships were reported on
the respective returns of Carlco, TMT, and BWK at that time, and
Carlco, TMT, and BWK were no longer members of the consolidated
group of IRA for tax purposes.
a. Zeus 1984 Through 1988
IRA's consolidated returns for 1984 through 1988 reported
the following income, net assets, and stockholder equity with
respect to Zeus:
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