Investment Research Associates - Page 384




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               Meyers was the sole director of Administration Co. and was             
          its president from 1981 to 1985.  Gallenberger was the vice                 
          president of Administration Co. and worked under the direction of           
          Meyers.  When Meyers left Administration Co. in 1985, Kanter                
          briefly served as acting president of Administration Co., and,              
          thereafter, Gallenberger became Administration Co.'s president              
          from 1985 through 1988.10                                                   
               Administration Co. had several employees, mostly clerical              
          assistants, bookkeepers, and accountants.  Meyers directed the              
          staff and employees of Administration Co. until 1985.  In 1983,             
          Administration Co. paid $143,489 in employee compensation and               
          distributed over $500,000 as nonemployee compensation, including            
          $400,000 to the Rainbow Trusts (Rainbow Trust Nos. 1-25).                   
               Administration Co. administered funds that it collected from           
          or on behalf of various Kanter entities and associates, referred            
          to as clients.  Administration Co. clients included individuals             
          (including Kanter, Ballard, and Lisle), corporations (including             
          IRA, Holding Co., and their subsidiaries), partnerships, trusts,            
          various Kanter-related entities, and members of Kanter’s law                
          firm.                                                                       




          10                                                                          
               Gallenberger was an accountant.  Shortly after arriving in             
          Chicago, Illinois, she passed the certified public accountant's             
          examination.  Gallenberger became an employee of Administration             
          Co. in 1982.                                                                





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