Investment Research Associates - Page 288




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          $500,841 and $549,841 to Holding Co., respectively.  As of                   
          December 31, 1989, Kanter owed $600,000 to IRA.                              
               BRT contributed its interests in Ever Ritch Partners and                
          Broadway Properties to Northern Financial Corp. pursuant to a                
          section 351 transfer.  Kanter acted as agent or nominee for BRT.             
               Respondent subpoenaed both Weisgal, as trustee of BRT, and              
          Kanter for the books and records of BRT.  Other than tax returns             
          of BRT, neither Weisgal nor Kanter produced the documents                    
          requested by the subpoenas.                                                  
               In the early days of the law firm of Levenfeld and Kanter or            
          Levenfeld, Kanter, Baskes, and Lippitz (LK), Kanter began a                  
          practice within LK that, to the extent there were "investment                
          opportunities", the partners of the law firm would be advised of             
          them and would be offered the opportunity to participate to the              
          extent of their then existent partnership interests in the law               
          firm.  The partners could choose to participate on behalf of                 
          themselves, their family members, extended family, and/or through            
          entities such as trusts, partnerships, or corporations for the               
          benefit of their family.  Under this policy, if a partner did not            
          participate, his percentage was offered to the other partners.               
               In 1973, Charles F. Dolan (Dolan) was negotiating to                    
          purchase franchises for cable television from Time, Inc.  He had             
          met Kanter in the late 1960's.  At the direction of Kanter, Roger            
          S. Baskes (Baskes) attended a meeting with Dolan and Time, Inc.              






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