- 565 - bonds, and other security interests to MAF for nominal consideration.62 On December 17, 1987, IRA acquired notes receivable totaling $1,120,889 from IFI in cancellation of IFI's $507,648 note due to IRA. This transfer included the notes receivable listed above except those due from HELO and Cedilla Invest. in the amounts of $485,824 and $345,868, respectively. (This is the same transaction in which IRA acquired the Ballard, Lisle, and Abernathy notes previously discussed.) While the principal amounts of the notes acquired from IFI were greater than the amounts set forth above, through an adjusting journal entry IRA reduced the basis of these notes. On December 30, 1987, IRA sold the notes for $1 each to MAF in an attempt to establish worthlessness. Kanter testified that IRA knew that the notes were worthless at the time IRA acquired the notes from IFI. The transaction was entered into by IRA and IFI as a means to shift 62 Kanter assisted the CMB and RWL Trusts in obtaining these loans from IRA and IFI to permit the trusts to invest in various movie partnerships. The loans to the trusts essentially amounted to nonrecourse loans to Ballard and Lisle, as Ballard and Lisle had no legal obligation to repay the loans. However, because the trusts were grantor trusts, Ballard and Lisle claimed the tax benefits from the trusts' movie partnership investments on their respective individual income tax returns. During the year at issue, Cedilla Invest. was a subsidiary of IRA and is the same entity that was involved in the equipment leasing transactions considered in Issue 22. During 1983 and 1984, HELO was a subsidiary of Holding Co. Elk Investment and Inter Alia Investment had likewise borrowed funds to invest in unsuccessful movie partnerships.Page: Previous 555 556 557 558 559 560 561 562 563 564 565 566 567 568 569 570 571 572 573 574 Next
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