- 318 - two highly successful businessmen conspired to conceal millions of dollars of kickbacks, using a multitude of entities with friends and employees serving as officers of convenience, in an attempt to defraud the employers of Ballard and Lisle and evade taxes properly owed to the Government. As each layer of Kanter's complex organization is removed, and the flow of the money is followed, the magnitude of the fraud is revealed. Kanter's explanations are mere platitudes and rationalized rhetoric intended to obfuscate the true character of the transactions and his wrongdoing. F. Summary and Conclusions as to Fraud The addition to tax or penalty in the case of fraud is a civil sanction provided primarily as a safeguard for the protection of the revenue and to reimburse the Government for the heavy expense of investigation and the loss resulting from the taxpayer's fraud. Helvering v. Mitchell, 303 U.S. 391, 401 (1938). The facts, as we have found in detail, clearly show that Kanter, Ballard, and Lisle, through the use of various conduit entities, devised a multifaceted scheme to shield kickback payments they received from transactions involving the Five. Their fraud resulted in the Federal Government not being paid several millions in income taxes due and owing. Clearly, the Government incurred great expense investigating petitioners'Page: Previous 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322 323 324 325 326 327 Next
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