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During 1989, KWJ partnership paid the Lisle and the Ballard
children $36,000. Of the $36,000 paid, Lisle's children received
at least $18,000 and Ballard's children received at least
$12,000.32
None of the Ballard or the Lisle children performed any
services for KWJ Corp. or KWJ partnership. The Hyatt payments
and interest were the only sources of income KWJ Corp. or KWJ
partnership ever received.
In February 1990, after the Internal Revenue Service began
examining Ballard's, Kanter's, and Lisle's returns for the years
at issue, Kanter sent letters to the children terminating KWJ
Co’s. "consulting arrangement" with them. In the letters Kanter
stated that the children had done nothing for a number of years.
c. KWJ Partnership 1989 Payments to Lisle and Ballard
As noted earlier, Carlco, TMT, and BWK, Inc., organized the
KWJ Partnership. The Hyatt payments were issued by Hyatt to
Weaver who forwarded the payments to the KWJ Partnership, out of
which Weaver was paid his 30 percent and the balance was
distributed to Carlco, TMT, and BWK, Inc.
32
The record is unclear whether all four each received $9,000,
or whether Thomas Lisle, Amy Albrecht, and Karen Hart each
received $12,000. Melinda Ballard testified that she resigned
from KWJ Co. in 1988. If that was the case, then of the $36,000
paid by KWJ Co. in 1989, Thomas Lisle, Amy Albrecht, and Karen
Hart each received $12,000. If Melinda Ballard did not resign,
then each of the four children received $9,000 during 1989.
Thomas Lisle and Amy Albrecht together received at least $18,000
during 1989, and Ballard's children received at least $12,000.
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