-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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