Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 75

                                                -159-                                                   
                  Kanter reached a similar agreement with Lisle to discharge                            
            his debt to IRA.  Originally, pursuant to certain payment                                   
            negotiations Kanter and Lisle had in 1989, Lisle agreed to pay                              
            the debt in 2 years.  He failed to do so, and he and Kanter                                 
            discussed the matter again, until Lisle, at some point, agreed to                           
            pay the debt by the end of 1993.  However, Lisle died before                                
            making any payment, and Kanter, acting on behalf of IRA, filed a                            
            claim against Lisle’s estate.                                                               
                  Beginning in about 1990, Ballard was paid a salary by TMT,                            
            and Lisle was paid a salary by Carlco.  Kanter, who was now IRA’s                           
            president, agreed to have each of these IRA subsidiaries pay a                              
            salary to Ballard and Lisle.  Ballard had requested that TMT pay                            
            him a salary.  At various times from 1987 through 1989, some of                             
            Ballard’s family trusts had also received loans from TMT in order                           
            to make certain real estate investments.                                                    
            IV.  Additional Findings of Fact:  The Flow of Funds                                        
                  Other than the limited discussion concerning loans to                                 
            Ballard and Lisle and their family trusts set forth above, the                              
            STJ report did not include an analysis of the flow of funds that                            
            respondent offered as further proof that the payments from The                              
            Five constituted income earned by and properly taxable to Kanter,                           
            Ballard, and Lisle.  The following additional findings of fact                              
            focus on the payments from The Five to IRA, THC, and other                                  
            Kanter-related entities and how those funds were transferred to                             




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