Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 81

                                                -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.                                                                     





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