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Table 10
Year Amount
1983 $140,675
1984 54,201
1985 13,140
1986 326,783
1987 11,251,723
1988 1,332,565
1989 2613,298
1 In 1987, IRA sold stock (identified as Hyatt Air) and
received proceeds of $1,115,560. Exh. 22 (Form 6252); Exh. 9000,
at 4. IRA invested these proceeds in certificates of deposit
between 1987 and 1989. Exh. 34, at 1-2; Exh. 35.
2 In 1989, IRA’s cash on hand was reduced in substantial
part by a loan of $600,000 that IRA made to Kanter. Exh. 36, at
6; Exh. 9114, at 15.
Exhs. 18-24, Schedules L.
The remainder of this section is divided into two
subsections. Subsection 1 addresses all of the payments made by
The Five during 1977 through 1983. These payments were paid to
and accumulated by IRA and reported on IRA’s consolidated
returns. Subsection 2 addresses all of the payments made by The
Five during 1984 through 1989. These payments were paid to IRA
and/or other Kanter-related entities and distributed to Carlco,
TMT, and BWK, at a time when the latter entities were no longer
part of IRA’s consolidated group for tax reporting purposes.
1. Payments Made During 1977 Through 1983
As Table 9 reflects, during the period 1977 through 1983,
IRA received (1) $670,168 from Hyatt Corp. (70 percent of Hyatt
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