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below, we shall deny the estate’s motion and grant respondent’s
motion.1
Background2
A. Deficiency Proceedings
In Inv. Research Associates, Ltd. v. Commissioner, T.C.
Memo. 1999-407, a Memorandum Opinion filed in 28 consolidated
dockets, the Court held, inter alia, that Burton W. and Naomi R.
Kanter were liable for Federal income tax deficiencies and
additions to tax for the taxable years 1978, 1979, 1980, 1981,
1982, 1983, 1984, and 1986. The Court’s central holding in Inv.
Research Associates, Ltd. v. Commissioner, supra, sustained
respondent’s determination that Burton W. Kanter (Kanter)3 and
two associates, Claude Ballard (Ballard) and Robert Lisle
(Lisle),4 fraudulently attempted to evade tax by failing to
include in their taxable income certain kickback payments that
they received from a number of sources. The Court also sustained
1 Section references are to sections of the Internal
Revenue Code, as amended, and Rule references are to the Tax
Court Rules of Practice and Procedure.
2 The record reflects and/or the parties do not dispute the
following background facts.
3 Burton W. Kanter died on Oct. 31, 2001, after the trial
in the consolidated cases, and the Estate of Burton W. Kanter,
Deceased, Joshua S. Kanter, Independent Administrator was
substituted as a party in the Kanter deficiency cases.
4 Robert Lisle died before the trial in the consolidated
cases, and his estate was substituted as a party in his
deficiency cases.
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