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Ritch Trust group). See United States v. Administration Co., 74
AFTR 2d 94-5252, 94-2 USTC par.50,479 (N.D. Ill. 1994). On April
4, 1994, the District Court issued an order to show cause why the
Kanter-related entities should not be compelled to obey the four
summonses.
In connection with the instant cases, Gallenberger was
served by respondent with a discovery subpoena to produce
documents. On May 18, 1994, Gallenberger appeared at the
deposition without the requested documents. At the deposition,
Gallenberger stated that she did not have the records because of
a 3-year retention policy. Even under Gallenberger's alleged
records retention policy, however, documents of an individual or
entity under audit were not destroyed until the audit was
completed.
On the following day, May 19, 1994, a hearing was held in
the District Court on the Government's motion to enforce the
administrative summonses. At the hearing, Weisgal, who was
served as the named trustee of the BK Childrens Trust, admitted
that, after he received the summons, some of the documents,
including documents relating to the Kanters, had been turned over
to Administration Co. and that some had been discarded as part of
a 3-year record retention and discard policy.
Gallenberger, who had been served with summonses as
president of Administration Co., Principal Services, and
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