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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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