Investment Research Associates - Page 397




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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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