-163-                                                   
            Corp.’s payments to KWJ Corp.),85 $882,042 from Frey (through                               
            payments to IRA’s subsidiary, Zeus), (3) $1,398,626 from                                    
            Schaffel, (4) $1,941,505 from Schnitzer/PMS (through installment                            
                  85  During 1977 through 1983, Hyatt Corp. paid a total of                             
            $907,845 to KWJ Corp. pursuant to the Hyatt/KWJ agreement.  See                             
            Table 2, supra p. 90.  In early 1979, IRA acquired from Weaver                              
            all of KWJ Corp.’s common stock for $150,000.  At the time, KWJ                             
            Corp. had net assets of $115,084.  The record also leaves open                              
            the possibility that Hyatt Corp. made a payment to KWJ Corp. for                            
            1978 (a payment that would have been made in early 1979).  See                              
            supra p. 90 (Handelsman).  After 1978, Weaver forwarded the Hyatt                           
            Corp. payments to Kanter, who had TACI negotiate the checks and                             
            then distribute to Weaver his 30-percent share of each payment.                             
            Petitioners’ Reply Brief at 537.  IRA deducted the payments to                              
            Weaver as a commission expense.  With the exception of interest                             
            income of $13,796, the payments from Hyatt Corp. represented KWJ                            
            Corp.’s sole source of funds.  Exh. 9076 (Kuck Summary # 2.b.);                             
            Exh. 10, at 15; Exh. 14, at 6; Exh. 17, at 15; Exh. 18, at 19;                              
            Kuck, Transcr. at 3445-3446.                                                                
                  KWJ Corp.’s total application of funds for 1979 through 1983                          
            was approximately $674,900 as follows:                                                      
            Year                 Application    Amount          Exhibit                                 
                  1979        Dividend to IRA   $60,000   10, at 4, sched. M-2,                         
                                                             Kuck, Transcr. at                          
            3446                                                                                        
                  1980 --       --         --                                                           
                  1981/82     Dividend to IRA   260,000   14, at 40, l. 5                               
                                                       17, at 27; l. 28                                 
            25, at 21; Kuck,                                                                            
            Transcr. at 3446-                                                                           
            3447                                                                                        
                  1983        Dividend to IRA   297,900   18, at 30                                     
                  1982        Consulting Fees    21,000   17, at 16, l. 23                              
                  1983        Consulting Fees    36,000   18, at 20                                     
              Total                    674,900                                                          
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