Investment Research Associates - Page 240




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              Ballard discarded and permitted others, including Kanter,                
         Gallenberger, and Weisgal, to discard supporting income                       
         documentation, an intentional act designed to conceal and evade               
         the reporting and payment of Federal income tax.                              
              Ballard allowed Kanter to commingle his share of the                     
         kickback moneys in the laundering mechanism Kanter used to                    
         conceal its identity.  Ballard’s use of the various Kanter sham               
         entities (including among others, IRA, TMT, KWJ Corp., KWJ Co.,               
         Essex, Zeus, Holding Co., Int’l Films, HELO, Administration Co.,              
         and Principal Services) made it difficult and sometimes                       
         impossible to trace the cash-flow and is substantial evidence of              
         Ballard’s intent to evade tax.  Commingling the kickbacks in the              
         accounts of the conduit entities, together with other unrelated               
         income, was a device to hide the kickbacks from Prudential and                
         the IRS, and is evidence of Ballard's fraud.                                  
              Ballard plainly attempted to disguise the source of the                  
         kickback funds by funneling money in the roundabout method                    
         through the conduit entities over a period of many years.                     
              Ballard made the following misleading and false statements:              
              (1) He testified that at the dinner meeting where Kanter                 
         introduced Schaffel to Ballard and Lisle, they only discussed                 
         politics, football, and religion, and that no business was                    
         discussed;                                                                    








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