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(i). Transfers From Zeus to IRA
The payments that Zeus received from BJF from 1980 through
1983, a total of $882,042, accumulated in Zeus until they were
transferred to IRA in the steps outlined below.
(1) At a time unknown, but before March 25, 1983, IRA lent
Zeus $51,000. Exh. 26, at 24, last item.
(2) On March 25, 1983, Zeus transferred $51,000 to IRA as a
loan repayment. Exh. 26, at 24, last item.
(3) At a time unknown, but before October 21, 1983, IRA
transferred $774,000 or a cash equivalent to THC in exchange for
a receivable of $774,000 due from THC. Exh. 27, at 5 (AJE-25);
Exh. 26, at 11 (11-22-83); Petitioners’ Reply Brief at 491-492.
(4) On October 21, 1983, Zeus transferred $774,000 to IRA
in exchange for the $774,000 THC receivable. Exh. 27, at 5 (AJE-
25); Exh. 26, at 11 (11-22-83).
(5) At a time unknown, but before December 5, 1983, IRA
transferred $13,000 or a cash equivalent to THC in exchange for a
receivable of $13,000 due from THC. Exh. 26, at 23.
(6) On December 5, 1983, Zeus transferred $13,000 to IRA in
exchange for a $13,000 THC receivable. Exh. 26, at 23; Kuck,
Transcr. at 3428-3443. Thus, at the end of 1983, Zeus retained
$44,042 of the $882,042 paid by BJF, and Zeus held THC notes
receivable totaling $787,000.
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