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the area of Federal tax law. For a number of years, he has been
a writer and contributor to the Journal of Taxation, a national
monthly publication devoted exclusively to Federal taxation.
Kanter, as an experienced tax attorney, obviously understood and
fully appreciated his legal obligations to report income
correctly and to pay taxes on that income. Nevertheless, he
disregarded these obligations by conceiving and carrying out
various schemes to misdirect income. Furthermore, he was or
should have been aware that his Federal income tax liabilities
were substantially underreported for each of the years in issue.
Second, as we have previously found, Kanter reported
adjusted gross losses on his Federal income tax returns for every
year from 1978 through 1989. For 11 of those years he paid no
Federal income taxes, and only minimum tax of $1,671 in 1978.
Kanter omitted income received from transactions with the Five
during the years 1978 through 1989 (except for 1985) in the total
amount of $3,422,469. Even for 1985, a year not before us here,
he omitted $1,592,939.
Third, Kanter created a complex laundering mechanism made up
of sham corporations and entities (including among others, IRA,
Carlco, TMT, BWK, Inc., KWJ Corp., KWJ Co., Essex, Zeus, Holding
Co., Int’l Films, HELO, Administration Co., and Principal
Services) to receive, distribute, and conceal his income, as well
as Ballard’s and Lisle’s income. Payments made for their
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