-89-
Beginning in 1984, the Hyatt Corp. payments that Weaver
continued to forward to Kanter were no longer reported on IRA’s
consolidated returns. Rather, Carlco, TMT, and BWK reported
their distributive shares of this money passed through to them
from KWJ Partnership. Exhs. 69-74 (Carlco general ledgers);
Exhs. 93-98 (TMT general ledgers); Exhs. 114-119 (BWK general
ledgers).
In August 1992, after the IRS began its examination in these
cases, Kanter informed Hyatt Corp. that IRA had purchased and
later liquidated KWJ Corp., and that KWJ Corp.’s assets were
transferred to Carlco, TMT, and BWK and then contributed to KWJ
Partnership. Exh. 9104. As of the time of trial, Hyatt Corp.
continued to send its payments to Weaver in the form of checks
made payable to KWJ Corp. Handelsman, Transcr. at 1137.
During the period 1977 to 1994, Hyatt paid to KWJ Corp. the
amounts set forth in the following table.48
48 Hyatt Corp.’s records are inconsistent with IRA’s
records with regard to the years in which the payments listed
above were paid. We rely on Hyatt Corp.’s records regarding the
timing of the payments for purposes of these cases.
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