-175-
KWJ Partnership’s total source of funds during the
years 1984 through 1989 was $1,359,691, which included capital
contributions of $6,100, Hyatt Corp. payments of $1,103,721, and
IRA loans of $249,870. Petitioners’ Reply Brief at 538.
IRA made loans to KWJ Partnership totaling $30,000, $45,000,
$38,000, $48,000, $20,000, and $68,000 during 1984 to 1989,
respectively. See app. 5 to this report. As of July 30, 1990
(the date KWJ Partnership filed its tax return for 1989), these
loans had not been repaid. Exh. 957. These loans provided a
large portion of the funds KWJ Partnership used to make
consulting payments to Ballard’s and Lisle’s children as
discussed in additional findings of fact infra pp. 192-194.
During 1984 to 1989, Carlco’s, TMT’s, and BWK’s distributive
shares of the Hyatt Corp. payments to KWJ Corp. were $496,539,
$496,539, and $110,342, respectively. Exhs. 61-66, 84-89, 106-
111; Petitioners’ Reply Brief at 538.
One additional matter regarding the Hyatt Corp. payments
deserves mention. On August 2, 1989, IRA issued checks of
$22,619 each to Ballard and Lisle. After the checks were issued
to Ballard and Lisle, IRA records reflected a transfer of $45,237
to KWJ Partnership on August 8, 1989. Also on August 8 and 15,
1989, IRA ledger entries reflected that the checks issued to
Lisle and Ballard, respectively, were void. Exh. 36, at 9.
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