-152-                                                   
            Partnership apparently was not informed of the transfer and                                 
            continued to make partnership distributions to IRA.  Petitioners’                           
            Reply Brief at 534.                                                                         
                  k.  Payments to Essex Partnership and Essex Partnership                               
                  Distributions                                                                         
                  During 1982 to 1988, Essex Partnership reported that it                               
            received or accrued commission/consulting fee payments from GHM                             
            and MHM as follows:                                                                         
            Year         GHM          MHM              Exhibits                                         
            1982      $234,170     $104,121     9074, at 2, acct. Nos.                                  
            400100 and 400200                                                                           
            1983       222,557      235,718     707, at 1; Exh. 678,                                    
            statement 1                                                                                 
            1984       268,663      242,116     726, 353                                                
            1985       225,487      230,847     4010, 354, statement 1                                  
            1986        68,000      123,089     4011, 355, statement 1                                  
            1987       172,963      388,632     837, 356                                                
            1988       142,761      238,889     828, 357                                                
            Total  1,334,601    1,563,412                                                               
            For the 1989 taxable year, Essex Partnership reported $293,261 in                           
            total income from consulting fees from MHM and GHM.  Exh. 358,                              
            supporting schedule at 1.                                                                   
                  For the taxable years 1982 through 1989, Essex Partnership                            
            made distributions to IRA, THC, Connolly, and MHM as set forth in                           
            the following table.                                                                        
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