-194-
number of years”. Exh. 476. Kanter explained why Albrecht
continued to receive the monthly payments as follows:
Regrettably, from * * * [IRA’s] point of view (clearly
not yours), Mr. Freeman was preoccupied during that
time with other personal difficulties that were
protracted and distractive of his attention in
virtually every respect. I do not believe you are
aware of any of those difficulties and there is no need
to dwell on the point, other than to tell you that
during that time, he paid no attention to the
activities of * * * [IRA] and its affiliates, and those
who were simply administering tasks on behalf of * * *
[IRA] routinely continued to make payments to you since
they had no contrary instructions.
Exh. 476, at 2; Albrecht, Transcr. at 921. The record includes a
nearly identical letter that Kanter wrote to Thomas Lisle. Exh.
9099; Thomas Lisle, Transcr. at 937.
2. Additional Loans
a. IRA Loans to Kanter
IRA lent various amounts to Kanter during the period 1982 to
1989. Exhs. 25, 26, 29, 32-36. By the end of 1989, Kanter owed
$600,000 to IRA. Exh. 36, at 6. There is no evidence of notes
for these loans, and there is no evidence that any principal or
interest was paid on these loans.
b. Loans to Ballard, Lisle, Their Family Members,
and Their Trusts
(i). Ballard’s Grantor Trusts
Ballard was the settlor of the following grantor trusts,
with the trustees and beneficiaries, as indicated:
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