-164- payments of principal and interest), and (5) $164,588 from Eulich/Essex Partnership, for a total of $5,056,929. Before 1984, all payments that IRA and its subsidiaries received from The Five in connection with the Prudential transactions described above were reported on IRA’s consolidated returns. No tax was paid on this income because, during 1978 through 1983, IRA reported substantial net operating losses. See Table 1, supra p. 48. 2. Payments Made During 1984 to 1989 After 1983, Kanter altered the structure for the receipt of payments from The Five. Although Hyatt continued to issue checks payable to KWJ Corp., IRA (which purchased KWJ Corp. in 1979) liquidated the company in December 1983. At the same time, Carlco, TMT, and BWK formed the KWJ Partnership, which began receiving the Hyatt payments. Thereafter, the Hyatt payments were no longer reported on IRA’s consolidated returns but were reported on the respective returns of Carlco, TMT, and BWK in accordance with their distributive shares (45/45/10 percent, respectively) of KWJ Partnership items. Exhs. 61-66 (Carlco); Exhs. 84-89 (TMT); Exhs. 106-111 (BWK). In 1984, in connection with Lisle’s move to Travelers, Schaffel made a final payment of $213,750 to IRA and then began making payments to THC.Page: Previous 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 Next
Last modified: May 25, 2011