- 48 -
08/78 08/79 08/80 08/81 08/83 08/84
Income -- -- $1,485 $4,597 -- $136
Deductions -- ($115) (31,309) (149,974) -- (30)
Total -- (115) (29,824) (145,377) -- 106
NOL -- (115) (29,939) -- (198,135)
Taxable -- (29,939) (175,316) -- (198,029)
Assets
Cash $500 131 4,294 (879,704) $31 322
Receivables -- -- 2,871,082 4,691,912 2,331,326 1,320,059
Money market -- -- 718 259 -- --
Pooled funds -- -- -- -- -- 4,636
Intangibles 151 120 89 27
Total 500 382 2,876,214 3,812,556 2,331,384 1,325,017
Liabilities
Short term -- -- 322,987 849,680 2,518,589 1,522,700
Shareholder -- -- 1,255,600 10,557 -- --
Long term -- -- 1,327,100 3,127,200 10,557
Total -- -- 2,905,687 3,987,437 2,529,146 1,522,700
Net assets 500 382 (29,473) (174,881) (197,762) (197,683)
500
Capital stock 500 500 500 500 500
Ret. earnings (118) (29,973) (175,381) (198,262) (198,183)
2. Int'l Films
Int'l Films was incorporated in September 1973. Although
the record does not disclose who originally owned the stock of
Int'l Films, on August 31, 1984, IRA owned 71 percent of the
voting stock of Int'l Films. As of August 31, 1983, Int'l Films
had loans receivable of $878,227. As of August 31, 1984, Int'l
Films had loans receivable of $1,050,827.
III. Transactions Involving the Five
Prior to and during the years at issue, Prudential was one
of the largest holders of commercial real estate in the United
States. By the late 1970's, Prudential either held or was
responsible for managing an estimated $20 billion in commercial
real estate properties. Prudential also developed commercial
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