-215-
PSAC, which purportedly possessed documents pertaining to Kanter,
Ballard, and Lisle (and related entities)).105
The summons to PSAC dated October 1, 1990, requested, in
part, documents pertaining to PSAC, IRA and its subsidiaries, THC
and its subsidiaries, BWK, and the Bea Ritch Trusts. The summons
requested production of the cash receipts journals, cash
disbursement journals, general ledgers, subsidiary ledgers, and
ledgers for all bank accounts including the TACI Special E
Account. Exh. 9046. The summons also requested production of
documents pertaining to any corporations or partnerships in which
Kanter, his family, and/or his family trusts were shareholders.
Id.
C. Summons Enforcement
In addition to the summonses described above, the IRS served
summonses on Administrative Enterprises, Inc. (predecessor to
PSAC), PSAC, Zion, and BK Children’s Trust (the four Kanter-
related entities) during 1990 and 1991. In 1994, the Government
filed with the U.S. District Court for the Northern District of
Illinois a petition to enforce the four summonses. On April 4,
1994, the District Court issued an order to show cause why the
four Kanter-related entities should not be compelled to comply
with the four summonses. The District Court conducted hearings
105 See app. 16 to this report.
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