Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 106

                                                -187-                                                   
            Business Activities and/or Private Investments Form.  Exh. 1029.                            
            In response to a direction to provide a “Complete description of                            
            the investment or business affiliation.  What is it and who else                            
            is involved in it as principals?  Does it involve a public or                               
            private company?”, Ballard answered, in part:  “Farmland--Have                              
            been buying and selling for years.”  Id.  Ballard did not                                   
            identify IRA or TMT as principals and/or private companies with                             
            regard to these activities.                                                                 
                  When Ballard became the director of an organization called                            
            ICM Property Investors, Ballard submitted to Goldman Sachs an                               
            “Outside Business Activities Information and Request Form”.  Exh.                           
            1031.  Ballard’s involvement with this organization was through a                           
            “close friend” who controlled the property.  Id.  In contrast,                              
            Ballard never submitted such a form to Goldman Sachs with respect                           
            to TMT, which he purportedly was managing for IRA at Kanter’s                               
            request.                                                                                    
                  (vi).  TMT’s Assets                                                                   
                  During 1984, 1985, and 1986, TMT had total assets of                                  
            $2,015,911, $2,289,151, and $2,520,852, respectively.  Exhs. 93,                            
            94, 95.  TMT’s cash holdings during 1984, 1985, and 1986 totaled                            
            $1,899,873, 1,906,516, and $50,803, respectively.  Id.  By 1986,                            
            TMT had transferred approximately $1.2 million to a Goldman Sachs                           







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