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$635,250 from Equitable Leasing Co., Inc. (Equitable Leasing).
The notice stated that the income "represents fee income which
was assigned to a related entity or the true nature otherwise
disguised".
Equitable Leasing made the following payments to Holding Co.
and Zion, a subsidiary of Holding Co.:
Form of
Date Payment Payee Amount
1-8-83 Bank transfer Zion $317,250
1-24-83 Check Holding Co. 9,500
6-1-83 Check Zion 6,500
6-30-83 Bank transfer Holding Co. 302,000
Total 635,250
The check dated January 24, 1983, to Holding Co. bore the
notation "commission". Holding Co.'s adjusting journal entries
identify the bank transfer of January 8, 1983, to Zion as
"commission income" for "commiss. from Eq Leasing". The record
does not show what the other two payments were for.
Equitable Leasing was the wholly owned company of Joel
Mallin (Mallin), who was a tax attorney, a former partner, and a
friend of Kanter. He was engaged in the business of selling and
promoting equipment leasing deals.
Kanter introduced investors to Mallin so that Mallin could
complete or close certain transactions. Kanter permitted Mallin
to use Zion as an investor and to make payments to Zion or
Holding Co.
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