Investment Research Associates - Page 396




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          trustee of each of the Bea Ritch Trusts.  Specifically, the                  
          assets sold to Windy City were all of the other assets described             
          in the table above except the Rooney Pace bond, which was sold to            
          Mallin, and the Brajdas Corp. stock, which was sold to an                    
          unrelated third party.                                                       
               Mallin was a former law partner of Kanter's who served on               
          the board of directors of Cedilla.  Mallin was extensively                   
          involved in equipment sale/leaseback transactions involving IRA              
          and Cedilla.  Those transactions are the subject of discussion in            
          Issue 22.  As noted above, Mallin purchased the Rooney Pace bond.            
               For the most part, the assets at issue were reflected as                
          acquisitions by Kanter that were paid for out of Kanter's special            
          E account with Administration Co.  As of December 31, 1986,                  
          Kanter's special E account balance with Administration Co. was a             
          negative $79,283.                                                            
               The Brajdas Corp. stock was purchased on April 20, 1987, for            
          $1,300 in the exercise of a warrant.  Kanter sold the stock to an            
          unrelated party on May 29, 1987, for $1,780, realizing a gain of             
          $476.  The record does not reflect the acquisition history of the            
          Flexible Computer stock, the Rooney Pace bond, or the Electronic             
          Missile stock.                                                               
               The IHOG stock was held by the Nominee Corp., a corporation             
          which apparently held assets for the equitable and beneficial                
          interest of Kanter.  It appears from the record that IHOG was not            






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