-269-
2. Payments to IRA: 1984 Through 1989
After 1983, the structure through which the payments were
received from The Five changed. Although Hyatt Corp. continued
to make payments to KWJ Corp., IRA had liquidated the company and
distributed its assets to Carlco, TMT, and BWK, which formed KWJ
Partnership in early 1984. Thereafter, the Hyatt Corp. payments
were distributed by IRA to KWJ Partnership and reported on the
returns of Carlco, TMT, and BWK. Similarly, IRA had transferred
its interest in Essex Partnership to Carlco, TMT, and BWK.
Thereafter, IRA no longer reported the distributive income from
Essex Partnership on its returns. Instead, the distributive
share of income was reported on the returns of Carlco, TMT, and
BWK, respectively.
During the period 1984 through 1989, The Five made payments
to IRA (and Zeus) in the aggregate amount of $4.6 million. IRA
distributed (1) $1,103,721 that it received from Hyatt Corp. to
KWJ Partnership (and to Carlco, TMT, and BWK), and (2) $623,865
that it received from Essex Partnership to Carlco, TMT, and BWK.
IRA also transferred to Carlco, TMT, and BWK $2,287,191 in
installment payments that it received from PMS during 1984 to
1989.
Although there is no direct evidence that Zeus transferred
to IRA the approximately $232,000 in payments that it received
from Frey during 1984 and 1985, that amount nearly equals the
Page: Previous 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 NextLast modified: May 25, 2011