Investment Research Associates - Page 414




                                       - 467 -                                         
                         Year            Amount                                        
                         1979           $46,049                                        
                         1980           13,778                                         
                         1983           56,280                                         
               Respondent disallowed in full the investment tax credit                 
          carryovers claimed by IRA for 1982 through 1987.                             
          1.   Schott                                                                  
               Schott was an officer and director of IRA in 1979.  Despite             
          the fact that IRA's Federal income tax returns indicate that                 
          Schott was a 50-percent owner of IRA, she had no knowledge                   
          regarding her participation in that entity as an equity owner.               
               Previously, Schott had been an officer of Cedilla Invest.               
          starting in 1974 or 1975.  She served as president of Cedilla                
          Invest., yet did not know what she did for the company.                      
               Schott executed documents on behalf of Cedilla Invest. with             
          respect to equipment leasing transactions without knowing who                
          prepared the documents or the purpose of the documents.  She did             
          not recall negotiating any leasing transactions on behalf of                 
          Cedilla Invest.                                                              
          2.   Mallin                                                                  
               Mallin was asked to be a director of Cedilla Invest. by                 
          Kanter, a friend and former law partner, at a time when Mallin               
          did not know who owned Cedilla Invest.  Mallin was generally not             
          familiar with IRA or Cedilla Invest. or their officers and                   
          directors.                                                                   







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