-170-
On January 12, 1984, Zeus transferred $5,028 to IRA in
exchange for a $5,028 THC receivable. Exh. 9070, at 2.
By the end of 1989, the THC receivables that Zeus received
from IRA had not been repaid. Exh. 9070, at 2, 7 (1984 and 1989
general ledgers). There is no evidence in the record that Zeus
ever accrued any interest or received any principal payment in
connection with the THC receivables identified above.
(ii). IRA’s Transfer of Its Interest in Essex Partnership
As previously mentioned, in December 1984 IRA distributed to
Carlco, TMT, and BWK its 26.125-percent partnership interest in
Essex Partnership. The details of that transaction are
summarized as follows.
In January of 1984, IRA recorded the receipt of a $44,413
payment received from Essex Partnership as payables of $19,986
due to each of Carlco and TMT and $4,441 due to BWK. Exh. 29, at
6. On January 30, 1984, IRA issued a check in the appropriate
amount to each of the corporations and recorded the payments as
payment of the payables owed to Carlco, TMT, and BWK. Exh. 29,
at 1. Additional distributions from Essex Partnership to IRA
during 1984 totaling $88,825 were also treated as distributed
directly to Carlco, TMT, and BWK, by reducing the additions to
capital attributable to IRA’s contributions of cash made to the
corporations during the year. Exh. 29, at 17.
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