-177-
record. IRA distributed these payments as payables to Carlco,
TMT, and BWK in a 45/45/10 percent split, and they in turn
reported their respective shares of these distributions on their
tax returns. Exhs. 61-66 (Carlco); Exhs. 84-89 (TMT); Exhs. 106-
111 (BWK). Essex Partnership income was allocated to Carlco,
TMT, and BWK during 1984 through 1989, as follows:
Year Carlco TMT BWK
1984 $59,957 $59,957 $13,324
1985 54,079 54,079 12,018
1986 36,210 36,210 8,047
1987 54,314 54,314 12,070
1988 52,903 52,903 11,756
1989 23,277 23,277 5,173
Total 280,740 280,740 62,388
Exhs. 29, 32-36.
c. Carlco, TMT, and BWK Capital Accounts
At the end of 1989, IRA’s records reflected that it made
capital contributions and transferred paid-in capital to Carlco,
TMT, and BWK as follows:
Carlco TMT BWK
$2,938,173 $3,320,267 $652,250
Exh. 74, at 12-13 (Carlco); Exh. 98, at 9 (TMT); Exh. 119, at 2
(BWK). The $382,094 difference between Carlco’s and TMT’s
capital accounts at the end of 1989 was attributable to TMT’s
accounting for so-called consent dividends during the period 1984
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