Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 74

                                                -158-                                                   
            Kanter’s, and Lisle’s respective returns for the years at issue,                            
            Kanter, in February 1990, sent letters to the children                                      
            terminating KWJ Partnership’s “consulting arrangement” with                                 
            them.83  In two of these termination letters, Kanter apprised the                           
            children that he had recently assumed IRA’s presidency.  He noted                           
            that their consulting arrangement had begun when Lawrence Freeman                           
            was IRA’s president.  In the letters, Kanter stated that the                                
            children had done nothing for a number of years, and he blamed                              
            Mr. Freeman for having KWJ Partnership continue to make monthly                             
            payments to them.84                                                                         
                  After becoming IRA’s acting president in 1989, Kanter also                            
            discussed with Ballard and with Lisle the payment of their                                  
            individual promissory notes that IRA held but had previously                                
            deducted as bad debts on IRA’s 1987 return.  Since at least 1987,                           
            Ballard had claimed that neither he nor his wife were liable on                             
            the promissory notes that they had previously executed.  In late                            
            1992, Ballard agreed to pay IRA $120,000 in settlement of his                               
            $196,000 debt to IRA on his promissory notes.  Ballard also                                 
            entered into an arrangement, at about this time, to repay the                               
            $160,000 loan his wife had received from TMT in July 1985.                                  


                  83  Melinda Ballard’s consulting arrangement had been                                 
            terminated earlier in late 1988.                                                            
                  84  Pertinent portions of the text of these letters are                               
            quoted infra pp. 193-194.                                                                   




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