-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 674,900Page: Previous 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 Next
Last modified: May 25, 2011