Investment Research Associates - Page 398




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          purportedly bought from IRA on December 1, 1985 for $10,000.                 
          Kanter paid no cash for this note.  His purchase of the note from            
          IRA was accomplished through an adjusting journal entry on the               
          books of IRA.                                                                
               Weisgal was trustee of the R Trust.  The R Trust issued a               
          $1,000 note to Holding Co. dated August 29, 1978; a $20,000 note             
          to Holding Co. dated November 21, 1979; and a $31,500 note to                
          Kanter dated February 2, 1978.  Through Administration Co.                   
          bookkeeping entries, Kanter acquired the notes receivable                    
          totaling $21,000 due from the R Trust to Holding Co. on August               
          29, 1986.  Kanter paid no cash for this note, but his amount due             
          to Administration Co. was increased by $21,000.  In 1988, in                 
          exchange for $10,000 of its $64,000 note payable to HELO, Zeus               
          acquired a $10,000 note receivable of the R Trust from HELO.                 
               Administration Co. wire-transferred $15,000 to Virginia                 
          Arlington F/C Arlington Carpentry, Inc. (Arlington), on November             
          27, 1985.  Administration Co. filed a financing statement that               
          covered Arlington's equipment and receivables.  Administration               
          Co. wired the funds to Arlington at Kanter's direction.  Kanter              
          did not know the individual at the head of Arlington.  However,              
          that individual was a friend of Kanter's son, Joel, who was                  
          having some work done by Arlington.  Joel asked Kanter to send               
          the money to Arlington, and Kanter agreed.                                   








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