-54- Exhs. 56, 79. Meyers was named trustee of the Christie and Orient trusts. Id. Members of Lisle’s family were named as beneficiaries of the Christie Trust, and members of Ballard’s family were named as beneficiaries of the Orient Trust. Id. Carlco, TMT, and BWK were so-called shelf corporations that Kanter first incorporated in 1982 but remained dormant until late 1983. Kanter, Transcr. at 3604-3605. In December 1983, IRA acquired 1,000 shares or 100 percent of the common stock of each of Carlco, TMT, and BWK. Exh. 18, at 7. IRA paid $6,000 to each of the corporations for the shares of stock. Exhs. 68, 92, 113. In December 1983 and January 1984, Carlco, TMT, and BWK each issued preferred shares of stock. Carlco preferred shares were issued to the Christie Trust (Lisle’s family trust); TMT preferred shares were issued to the Orient Trust (Ballard’s family trust); and BWK preferred shares were issued to the BK Children’s Trust (one of the Bea Ritch Trusts). As a result of those trusts’ ownership of these preferred shares, Carlco, TMT, and BWK no longer qualified to be members of IRA’s consolidated group of corporations for tax purposes and were not included in the consolidated returns IRA filed. For 1984 and thereafter, Carlco, TMT, and BWK, each filed separate Federal corporate income tax returns. The record does not include a complete setPage: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
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