- 313 - services were paid to IRA and Holding Co. or one of their subsidiaries. The payments were commingled with funds from other entities in Administration Co.’s accounts and later Principal Service’s accounts. Large amounts of money were distributed to various entities and individuals, including Kanter, Ballard, and Lisle, through IRA, Holding Co., HELO, Int’l Films, and the Bea Ritch trusts. The distributions were disguised as loans and recorded as receivables. The receivables were shuffled (through book entries) between the various entities and eventually written off. Kanter’s use of the various sham entities made it difficult and sometimes impossible to trace the flow of the money and is substantial evidence of his intent to evade tax. See Scallen v. Commissioner, 877 F.2d 1364, 1370-1271 (8th Cir. 1989). Fourth, as reflected in our findings of fact, Kanter did not cooperate with respondent's agents at various stages of their investigation of his tax returns. He withheld relevant documents and information involving transactions with the Five and the movement of moneys through the conduit entities such as Administration Co., IRA, Holding Co., and others. Kanter caused some records to be destroyed and attempted to place other records beyond the reach of the revenue agents conducting the investigation. We find in particular that destruction of records that were the subject of the IRS summonses after the issuance of the summonses to be a strong indication ofPage: Previous 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322 Next
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