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and Naomi R. Kanter, Claude M. and Mary B. Ballard, and Robert W.
and Donna M. Lisle, respectively.
The issues to be decided are:
(1) Whether payments made by the Five in the Prudential,
Travelers, and Kanter transactions during the years at issue are
properly taxable to Kanter, Ballard, and Lisle, and, if so,
whether they are liable for the fraud additions to tax and
penalty with respect to such income;
(2) whether certain commitment fees paid to Century
Industries, Ltd., are includable in Kanter's income for 1981,
1982, 1983, 1984, and 1986;
(3) whether Kanter received unreported income from Hi-
Chicago Trust for 1981, 1982, and 1983;
(4) whether Kanter is taxable on the income of the Bea
Ritch Trusts for 1986, and 1987;
(5) whether Kanter had unreported income for 1982, 1983,
1984, 1987, 1988, and 1989 from the CMS Investors Partnership;
(6) whether Kanter had unreported income in 1983 from
Equitable Leasing Co., Inc.;
(7) whether Kanter had unreported income in 1982 based on
the bank deposit analysis method;
(8) whether Kanter received barter income from Principal
Services in 1988 and 1989;
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