- 32 -
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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