-6- C. Other Means Used To Transfer Funds for the Benefit of Ballard, Lisle, Kanter, and Their Respective Families ................ 191 1. Payments From IRA, KWJ Corp., and KWJ Partnership .................. 191 a. IRA Payments to Ballard and Lisle in 1982 .............. 191 b. Consulting Fees Paid by KWJ Corp. and KWJ Partnership to Ballard’s and Lisle’s Adult Children ........ 192 2. Additional Loans ............... 194 a. IRA Loans to Kanter ........... 194 b. Loans to Ballard, Lisle, Their Family Members, and Their Trusts ....... 194 (i). Ballard’s Grantor Trusts .... 194 (ii). Lisle’s Grantor Trusts ..... 195 (iii). International Films, Inc. .... 196 (iv). Harbor Exchange Lending Operation 196 (v). Loans to Lisle and His Trusts. . 197 (vi). Loans to the Ballards and Their Trusts .......... 197 (vii). Writeoff of Loans and Claimed Losses. ............. 197 (viii). Loans to Lisle’s RWL Cinema Trust During 1988 to 1990 .... 205 D. Summary of Funds Paid by The Five to IRA and Disposition of Those Funds for the Benefit of Kanter, Ballard, Lisle, and Their Families .... 205 E. Payments Made by The Five to THC and Its Subsidiaries During 1981 Through 1989 ....... 207 F. Distribution of Funds From THC to Kanter ..... 208 G. The Flow of Funds From Four Ponds and One River Through FPC Subventure to Kanter and Lisle .... 211 V. Additional Findings of Fact Regarding the Examination Process and Summons Enforcement Proceedings ....... 213 A. Failure To Cooperate During the Audit ....... 213 B. IRS Summonses ................... 214 C. Summons Enforcement ................ 215 D. Requests for Production of Documents ....... 219 OPINION A. The Parties’ Positions .............. 222 B. The Assignment of Income Doctrine ......... 224 C. Errors in the STJ Report ............. 228 1. The STJ Report Reflects a Misunderstanding of Respondent’s Theory Regarding the Kickback Scheme .................... 229 2. Discussion Regarding Assignment of Income .. 231Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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