       -151-

activities occurred.    Formby, Transcr. at 1548-1549, 1555; Exhs.

348, 351.

     James, the president of MHM, could not identify a specific

person or entity who would have acted as a liaison between the

owners and operators of the hotel properties in question.     James,

Transcr. at 1735-1737.    James did not know that IRA and THC were

partners in Essex Partnership until he was shown the partnership

agreement at trial.    James, Transcr. at 1734-1737.

     There were no officers or employees at Essex Partnership who

could have engaged in consulting or acted as liaisons.      Formby,

Transcr. at 1534-1535.    Eulich had never seen the Essex

Partnership        Received (STJ report at 59-64)

     Ballard and Lisle established respective grantor trusts (the

CMB and the CMB II Trusts for Ballard and the RWL and the RWL II

Trusts for Lisle).   As grantor trusts, the income (or losses) of
                                -154-

the trusts was taxable to Ballard and Lisle pursuant to sections

671 through 678.   The CMB, CMB II, RWL, and RWL II Trusts each

made investments, as limited partners, in certain movie shelter

partnerships.    Kanter or Solomon Weisgal (the trustee of the Bea

Ritch Trusts