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information listed on the summonses to the agents during the
audit.
None of the above information requested was produced
pursuant to the summonses. In fact, petitioners did not produce
anything in response to the summonses, including documents
evidencing loans between themselves and the various entities.
Principal Services maintained Kanter's personal records, the
records of his family entities and trusts, the records of IRA and
Holding Co. Kanter controlled Principal Services and
Gallenberger. During discovery in these cases, respondent
requested receipts and disbursement journals for Holding Co. for
all of the years at issue. Kanter first promised to produce
Holding Co.'s books and records in the possession of Principal
Services and then, in early February 1994, notified respondent
that the Holding Co. was a third-party over which he had no
control. Initially, Gallenberger had in her possession the
records of Holding Co. for the years 1986, 1987, and 1988. After
respondent requested production of the Holding Co. records,
Kanter never asked Gallenberger for them. At some point,
however, she turned those records over to Kanter.
On April 1, 1994, the Government sought enforcement of four
summonses that had been served in 1990 and 1991 on Administrative
Enterprises, Principal Services, Zion, and BK Childrens Trust
(which is one of the twenty-five trusts which comprise the Bea
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