Investment Research Associates - Page 380




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          purchase.  Kanter directed Feigan to another of his clients, a               
          Mr. Rappaport (Rappaport), who lived in Switzerland.  Feigan and             
          Rapport thereafter agreed to a joint venture between them and,               
          through funds advanced by Rappaport, the painting was purchased.             
          After the purchase, it was discovered that the painting was not              
          by John Trumbull, and the seller agreed to a rescission of the               
          sale.  The seller paid back to the joint venture the amount of               
          the selling price, but in British currency.  That currency had               
          substantially declined in value against the U.S. dollar.  A                  
          dispute arose between Feigan and Rappaport.  Rappaport insisted              
          that he be returned the full value, in U.S. dollars, of the funds            
          he had advanced, and Feigan, on the other hand, refused to do so.            
          Kanter was drawn into the dispute ostensibly because of the role             
          he had played in putting Feigan and Rappaport together.  At                  
          Kanter's urging, Feigan agreed to make Rappaport whole, and                  
          Kanter contributed $104,231 toward the cause.  Kanter claimed                
          this amount as a trade or business expense on his 1980 income tax            
          return, which respondent disallowed.                                         
               Kanter was not contacted by Feigan for legal services or                
          legal advice, nor was it contemplated that Kanter would be paid              
          for his services.  Kanter was assisting two clients and friends              
          in a matter unrelated to Kanter's law practice or his activities             
          as a lawyer.  There were no legal services provided by Kanter.               
          Kanter was not a party to the joint venture between Feigan and               






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