- 563 -
its purported purchase of the notes from IRA. MAF never held
director or shareholder meetings.
During the years 1979 through 1989, Cedilla Invest. was a
subsidiary of IRA. Cedilla Invest. had total assets of
$10,008,632, $526,374, $526,374, and $575,896 on December 31,
1986, December 31, 1987, December 31, 1988, and December 31,
1989, respectively. Cedilla Invest. earned total income in the
amounts of $443,762, $52,656, and $11,702 for 1987, 1988, and
1989, respectively.
During 1983 and 1984, HELO was a subsidiary of Holding Co.
The proceeds of the "loans" to the Safari trust, CMB Cinema
Trust, CMB Cinema II Trust, RWL Trust, RWL Trust II, Elk
Investment, and Inter Alia Investment were used to invest in
unsuccessful film projects.
Ballard reported $41,697, $41,697, and $80 of income from
the CMB Cinema Trust II on his 1987, 1988, and 1989 returns,
respectively. Lisle reported $30 and $41,577 of income from the
RWL Cinema Trust II on his 1987 and 1988 returns. Ballard and
Lisle were, respectively, grantors of these trusts. See sec.
671.
With respect to the purported sales of notes receivable to
MAF in 1987, IRA failed to establish that it had any basis in the
notes.
Page: Previous 553 554 555 556 557 558 559 560 561 562 563 564 565 566 567 568 569 570 571 572 NextLast modified: May 25, 2011