Investment Research Associates - Page 83




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         B.   Flow of the Funds Paid By the Five Through IRA and Its                  
         Subsidiaries to Kanter, Ballard, and Lisle                                   
         1.   Overview                                                                
              The payments from the Prudential transactions were                      
         distributed by various means either directly to Ballard, Lisle,              
         and Kanter or indirectly through their family members or trusts              
         and other entities established for the benefit of their families.            
         Some distributions were recorded as receivables owed by the                  
         person or entity receiving the distribution; others were recorded            
         as consulting fees or director's fees.  Distributions from KWJ               
         Corp. and later KWJ partnership to Ballard's and Lisle's children            
         were treated as consulting fees.                                             
              In 1983, IRA began distributing the funds accumulated from              
         the Prudential transactions to Carlco, TMT, and BWK, Inc.  Lisle             
         was given control over the funds in Carlco, Ballard was given                
         control over the funds in TMT, and Kanter was given control over             
         the funds in BWK, Inc.  Lisle, Ballard, and Kanter treated the               
         funds as their own and used the funds for their personal benefit.            
         2.   Payments from IRA, KWJ Corp., and KWJ Co. Partnership                   
         a.   1982: IRA Payments to Ballard and Lisle                                 
              In 1982, Ballard received $12,500 from IRA as a "director's             
         fee".  The check was dated in 1981 but cashed in 1982.  On March             
         2, 1982, IRA paid Lisle $1,157.84.                                           









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