-171-
IRA recorded the distribution of the Essex Partnership
interest on its books as follows:
1984 beginning value $45,283
Less distribution of investment as paid-in capital (45,283)
Less distributions from Essex
5/8/84 (26,125)
7/6/84 (26,125)
10/4/84 (36,575)
Plus “distb exxex dist as pd in” 88,825
Investment end of year -0-
Exh. 29, at 17.
Lisle professed to have no knowledge that Carlco held an
interest in Essex Partnership. Exh. 2030, at 39.
(iii). IRA’s Transfer of Its Interest in Sherwood
Partnership
In December 1984, IRA also transferred to Carlco, TMT, and
BWK its 50-percent partnership interest in Sherwood Associates
Partnership (Sherwood), as more fully described below.
In 1982, IRA invested $175,000 in Sherwood and reported a
partnership loss of $89,577 for that year. Exh. 26, at 14.
In 1983, IRA invested an additional $150,000 in Sherwood and
reported a partnership loss of $287,165 for that year. Exh. 26,
at 30.
In 1984, IRA transferred its 50-percent partnership interest
in Sherwood to TMT (22.5 percent), Carlco (22.5 percent), and BWK
(5 percent). Exh. 9014 (AJE 7 for 12/31/84); Exh. 69, at 16;
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