-191-
returns reflect interest income from CDs only, and there is no
indication that Kanter paid any interest on the $400,000 loan.
Exhs. 107-111, 115-119.
During the period 1987 to 1989, BWK lent a total of $236,000
to PSAC to support its operations. Gallenberger, Transcr. at
1985-1986; Petitioners’ Reply Brief at 636. There is no evidence
that any principal or interest was paid to BWK on these loans.
Id.
(iii). Gifts
BWK’s general ledger for 1986 included an August 4, 1984,
entry for $1,000 which stated: “JANIS (Kanter) GIFT.” Exh.
2006. A subsequent entry in BWK’s general ledger suggests Kanter
reimbursed BWK for the above-referenced gift in March 1987. Id.
There is no suggestion in the ledger that Kanter paid BWK any
interest related to this transaction.
C. Other Means Used To Transfer Funds for the Benefit of
Ballard, Lisle, Kanter, and Their Respective Families
1. Payments From IRA, KWJ Corp., and KWJ Partnership
a. IRA Payments to Ballard and Lisle in 1982
In 1982, Ballard received $12,500 from IRA as a director’s
fee. Exh. 473. Ballard asserted he was not an IRA director and
the payment was for consulting services. Ballard, Transcr. at
218.
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