Investment Research Associates - Page 325




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          made as a protective measure "just in case" the agent                        
          subsequently discovered evidence to support it.                              
               Principal Services provided administrative and accounting               
          services to clients of Administrative Co. following                          
          Administration Co.'s financial difficulties and bankruptcy in                
          February 1988.                                                               
               Sometime in 1987, prior to Administration Co.'s filing for              
          bankruptcy, Administration Co. transferred to Principal Services             
          (which at that time had the name Administrative Enterprises)                 
          funds held in Administration Co.'s accounts, which contained                 
          funds of its clients.  Principal Services then established                   
          accounts similar to the Administration Co. special E and special             
          accounts.  The funds held in these accounts were considered to be            
          owned by clients of Principal Services.                                      
               Kanter performed minimal legal services for Principal                   
          Services in 1988 and 1989.  He did represent Principal Services              
          in litigation before this Court, but that did not begin until                
          1991.  There is no proof that the funds constituted barter income            
          to Kanter in 1988 and 1989.                                                  
                                       OPINION                                         
               Kanter contends that he received no barter income from                  
          Principal Services during 1988 and 1989.  He asserts that he did             
          not render any substantial services to Principal Services in                 
          those years and did not receive income from Principal Services.              






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