- 307 - (2) he told the agents that he was not aware of the dispute between Kanter and Schaffel regarding kickbacks for Travelers' deals; (3) he told the agents that he was not aware of any agreement between Schaffel and Kanter to share commissions Schaffel earned from the introduction to Ballard and Lisle. (4) he told the agents that Kanter mainly dealt with the field offices when introducing people to Prudential for business; (5) he denied any knowledge of the Christie Trust established for the benefit of his children; (6) he denied any knowledge of the Christie Trust's ownership of Carlco stock; and (7) he claimed that he had only recently learned about loans made by the Kanter entities to his family trusts and denied that any loans had been made to him. Lisle's pattern of consistent and substantial underreporting of income, along with other indicia indicating an intent to conceal income, justifies our finding that Lisle's underpayment of tax attributable to the income he omitted from transactions involving the Five is attributable to fraud. 2. Ballard's Fraud Respondent has proven by clear and convincing evidence that Ballard underpaid his taxes for each of the years at issue attributable to omitted income from transactions related to thePage: Previous 297 298 299 300 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 Next
Last modified: May 25, 2011