-297-
purposes, and they were nothing more than the alter egos of their
masters.
The following schedule lists the total amounts of payments
from The Five to IRA during 1977 to 1989 and the portions of
those payments that constitute income properly attributable to
Kanter, Ballard, and Lisle:
Total payments
Year To IRA1 Kanter Ballard Lisle
1977 $54,848 -- -– --
1978 60,739 $6,074 $27,333 $27,333
1979 250,000 13,636 61,364 61,364
1980 1,025,436 56,899 455,310 455,310
1981 1,092,055 107,842 485,289 485,289
1982 1,606,837 159,321 716,940 716,940
1983 967,014 95,338 429,020 429,020
1984 784,524 77,089 346,899 346,899
1985 817,420 80,379 361,703 361,703
1986 673,421 65,979 296,903 296,903
1987 711,839 69,821 314,191 314,191
1988 676,603 66,297 298,335 298,335
1989 944,927 93,129 419,081 419,081
1 The Court is not persuaded that Ross’s testimony regarding
the manner in which Century valued PMS when it purchased the
company in 1974 provides a sound basis for determining the value
of PMS stock when IRA purchased PMS shares in 1977 or when IRA
sold those PMS shares in 1979. Consequently, we have accounted
for the Schnitzer/PMS installment payments to IRA during 1979 to
1989 (see table 7, supra, p. 131) by reducing the total principal
payment for each year by $13,636 to reflect the return of the
$150,000 that IRA paid for the PMS shares in 1977 (i.e.,
$150,000/11 years = $13,636 per year).
The following schedule lists the total amounts Schaffel,
Frey, and Eulich/Essex Partnership paid to THC during 1981 to
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