Investment Research Associates - Page 245




                                       - 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 of              






Page:  Previous  303  304  305  306  307  308  309  310  311  312  313  314  315  316  317  318  319  320  321  322  Next

Last modified: May 25, 2011