Investment Research Associates - Page 238




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              (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 the               






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