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wholly owned by the Nominee Corp. The IHOG stock at issue was
acquired on October 7, 1986, through a check issued by
Administration Co. out of Kanter's account, payable to IHOG, in
the amount of $10,000. On February 11, 1987, IHOG paid $5,000 to
the Nominee Corp. as a "return of capital". Thus, Kanter claimed
a basis of $5,000 in this stock. In a letter accompanying the
payment of the $5,000 to the Nominee Corp. it was stated that
efforts were continuing to pursue the further development and
sales of IHOG's product, the nature of which was not indicated in
the letter.
Funds were advanced to Victorian Village from the
Administration Co. special E Account, and Victorian Village
issued notes payable to Nominee Corp.
Kanter issued a check to S. Block dated February 14, 1984,
in the amount of $5,000, bearing the notation "loan". Block
executed a $16,130.53 note to Kanter, dated July 1, 1985.
Administration Co. special E Account issued a check to Block in
the amount of $3,000, dated December 12, 1984. Block executed a
$10,000 note to Administrative Enterprises special E Account,
dated January 21, 1987. Although the record is not at all clear,
there is apparently no dispute that the balance due on the Block
note or notes was $23,356 on the date of sale, December 22, 1987.
The Tanglewood note receivable is the same note receivable
from Tanglewood to IRA in the amount of $350,000 that Kanter
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