-210-                                                   
                  Transfer            Amount     Appendix                                               
                  1983 (loans)            $407,458       11                                             
                  1984 (loans)            909,000       12                                              
                  1983 (retainer fees)      24,000       13                                             
                  1984 (retainer fees)      24,000       14                                             
                  1984 (loans)                161,000       15                                          
            Total                1,525,458                                                              
            Exh. 9078; Petitioners’ Reply Brief at 654-655.                                             
                  Kanter’s personal bank account records for the period                                 
            December 1982 through December 1984 show that Kanter made                                   
            withdrawals for his personal benefit and the benefit of his                                 
            family.  Exh. 5408 (items 1-730); Petitioners’ Reply Brief at                               
            652-653.                                                                                    
                  As of October 31, 1987, Kanter had outstanding loans from                             
            TACI totaling $1,346,641.  Exh. 9113; Petitioners’ Reply Brief at                           
            656-657.                                                                                    
                  As discussed, supra pp. 64-65, TACI filed for bankruptcy in                           
            February 1988.  Lawrence Korrub, TACI’s bankruptcy attorney,                                
            never received the records that TACI maintained for Kanter and                              
            his related entities because Gallenberger sent TACI’s books and                             
            records, including the bank statements and canceled checks                                  
            related to the TACI Special E and TACI Special Accounts, to                                 
            Kanter.  Gallenberger, Transcr. at 1970-1973.  There is no                                  
            evidence of notes for any of the funds transferred from the TACI                            
            accounts to Kanter’s personal bank account, nor is there any                                
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