Investment Research Associates - Page 252




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          well as funds of other Kanter entities and associates, were                 
          commingled in accounts administered by another Kanter controlled            
          entity, The Administration Co. (Administration Co.) (and later              
          Principal Services Corp.).                                                  
               Some distributions to Kanter, Ballard, and Lisle were                  
          characterized as commissions, consulting fees, or directors fees.           
          Others were recorded as receivables or loans, many of which were            
          traded or transferred between the various entities and eventually           
          written off as uncollectible with IRA and/or Kanter taking                  
          deductions for the writeoffs.  Some of the distributions that               
          were treated as loans were made through two Kanter entities,                
          International Films, Inc. (Int'l Films) and Harbor Exchange                 
          Lending Operation (HELO).                                                   
               Large portions of the payments made in the Prudential                  
          transactions eventually were distributed to three of IRA's                  
          subsidiaries; more specifically, 45 percent to Carlco, Inc.                 
          (Carlco) (controlled by Lisle), 45 percent to TMT, Inc. (TMT),              
          (controlled by Ballard), and 10 percent to BWK, Inc. (controlled            
          by Kanter).                                                                 
               An overview of the Kanter enterprise is shown by the                   
          following diagram:                                                          











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