-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 set
Page: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 NextLast modified: May 25, 2011