-214- In connection with the Kanter examination, IRS agents interviewed Lisle on January 10, 1990 (Exh. 2030), and Ballard in February 1990. Lunk, Transcr. at 1040. After these interviews, the IRS began to examine Lisle’s and Ballard’s tax returns. It was during this period that (1) Kanter wrote to Ballard’s and Lisle’s children and explained that he was terminating their purported consulting agreements, (2) Ballard and Lisle began to be paid for managing Carlco and TMT, and (3) Kanter began to negotiate with Ballard and Lisle regarding the loans IRA wrote off as bad debts in 1987. During the examination process, Kanter, Ballard, Lisle, and their associates failed to produce information the IRS requested orally and/or through written information document requests. Lunk, Transcr. at 1042-1050, 1059. Kanter produced only documents related to Schedule A deductions under examination. Lunk, Transcr. at 1056-1057; Dion, Transcr. at 832-835, 837-838. Kanter, Ballard, and Lisle failed to produce records sought by the IRS concerning their grantor trusts and other related entities. Lunk, Transcr. at 1057-1058. B. IRS Summonses The IRS issued summonses to Ballard, Lisle, Schott, and Gallenberger (in her individual capacity and as an officer ofPage: Previous 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 Next
Last modified: May 25, 2011