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wealthy investors to Frey’s projects not involving Prudential
properties.
During 1982 through 1989, Essex Partnership made payments to
THC totaling $645,009 representing cash distributions on THC’s
partnership interest. These payments served to compensate Kanter
for obtaining hotel management contracts for MHM.
F. Distribution of Funds From THC to Kanter
The payments THC received from Schaffel, Frey, and Essex
Partnership during the years at issue generally were deposited
into THC’s bank account. Petitioners’ Reply Brief at 646.
During 1983, THC transferred $2,335,298 from its account to
TACI’s accounts. Exhs. 148, 149, 174; Petitioners’ Reply Brief
at 646.100 These transfers were identified in THC’s general
ledgers as investments, loans, or repayments of loans.
Petitioners’ Reply Brief at 647. During 1983, $1,339,843 was
transferred from TACI’s accounts back to THC identified as
returns on THC’s investments, loans from TACI, and repayments of
earlier loans from THC to TACI. Exh. 5406, Petitioners’ Reply
100 See app. 7 to this report.
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