-165-
Frey continued to make payments to IRA’s subsidiary Zeus
during 1984 and 1985.
Schnitzer/PMS continued to make principal and interest
payments to IRA with the exception of its final (accelerated)
payment, which was remitted to PSAC and then distributed to
Carlco, TMT, and BWK.
In December 1984, IRA transferred its interest in Essex
Partnership to Carlco (45 percent), TMT (45 percent), and BWK (10
percent). See discussion infra pp. 170-171. Therefore, IRA no
longer reported income from Essex Partnership on its consolidated
returns. Although Essex Partnership continued to make payments
to IRA, those payments were transferred to Carlco, TMT, and BWK,
which reported the payments in accordance with their distributive
shares of Essex Partnership items. Exhs. 61-66 (Carlco); Exhs.
84-89 (TMT); Exhs. 106-111 (BWK).
As Table 9 reflects, during the period 1984 to 1989, IRA
received (1) $1,103,721 from Hyatt Corp. (through payments to KWJ
Corp.),86 $232,263 from Frey (through payments to Zeus), (3)
$2,648,883 from Schnitzer/PMS (through installment payments of
86 During 1984 through 1989, Hyatt Corp. continued to issue
checks to Weaver made payable to KWJ Corp., and Weaver continued
to forward those checks to Kanter. After Kanter’s office
returned 30 percent of the payments to Weaver, KWJ Partnership
received the balance or $1,103,721.
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