-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.Page: Previous 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 Next
Last modified: May 25, 2011