Investment Research Associates - Page 294




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               Kanter was the owner of the interests of BRT in LICCDC (or              
          Cablevision), including, but not limited to, BRT's interests in              
          OBA, HB, BW, and YP.                                                         
               During the years 1981 to 1986, certain income that Kanter               
          earned was credited to BRT's capital account with Century                    
          Industries.  (See Century Industries Findings of Fact).  Century             
          Industries distributed $4,900 to BRT in each of the years 1982,              
          1983, and 1984.                                                              
               Kanter earned half the income distributed by Century                    
          Industries to BRT.  (See Century Industries Findings of Fact).               
               IRA, Holding Co., and Windy City were three of Kanter's sham            
          corporations used by Kanter to conceal and shift his income.  BRT            
          was the sole shareholder of IRA and Windy City and was a                     
          substantial shareholder of Holding Co.                                       
               Kanter assigned substantial amounts of his income to IRA and            
          Holding Co.  Kanter transferred assets to Windy City for less                
          than adequate consideration, thereby increasing the value of                 
          BRT's stock in Windy City.  Kanter sold "notes receivable" or                
          stock to Windy City for nominal consideration and claimed a loss             
          on the transfer.  The receivables, however, had value.  The                  
          transfers of stock and receivables increased the value of BRT's              
          stock in Windy City to the extent the value of the notes                     
          receivable or stock exceeded the nominal consideration paid by               
          Windy City.                                                                  






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