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of the corporate entities as controlling petitioners' performance
of services. Even though the payments were made to various
corporations, it is clear that the other parties to the
transactions viewed IRA, Holding Co., their subsidiaries, and
Kanter as one and the same. Although the various agreements at
issue were between members of the Five and IRA, Holding Co., or
one of their subsidiaries, the record shows that there was
virtually no involvement in these arrangements by those
corporations; rather, they were agreements with the corporations
in name only.
Additionally, assuming IRA was not a sham corporation, the
purchase of the KWJ Corp. stock was merely a device to hide the
stream of income and accumulate the funds. The transaction
itself was a sham. Similarly with the purchase of the Schnitzer-
PMS stock, Schnitzer would have sold the stock directly to
Kanter. He sold it at a bargain price for Kanter's services, not
for any services from IRA, Weisgal, or Schott. It is also clear
from the flow of the installment payments on Schnitzer's
repurchase of the stock that IRA either held the stock merely as
a nominee for Kanter, Ballard, and Lisle, or agreed to pay the
money it received from the Schnitzer-PMS transaction to Ballard,
Lisle, and Kanter in exchange for their assistance in giving more
Prudential business to Schnitzer-PMS. The increase in the
Prudential business greatly increased the pretax income and,
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