-216-
related to the Government’s petition on April 20 and May 19,
1994. At the latter hearing, Weisgal testified that at the time
he received the summons served on him as trustee of the BK
Children’s Trust (one of the 25 Bea Ritch Trusts), some of the
documents, including documents relating to the Kanters, had been
turned over to TACI and some documents had been discarded as part
of a 3-year record retention and discard policy. See United
States v. Administration Co., 74 AFTR 2d 94-5252, 94-2 USTC par.
50,479 (N.D. Ill. 1994); Exh. 9047--Mem. Op. and Ord. of May 20,
1994.
Gallenberger testified at the May 19, 1994, hearing that
documents relating to TACI were never returned to her from TACI’s
bankruptcy counsel.106 She testified that many records of PSAC,
Administrative Enterprises, Zion, and the Kanters no longer
existed. Gallenberger testified that she disposed of some
106 During TACI’s bankruptcy proceeding, the only documents
that Korrub, TACI’s bankruptcy counsel, may have received from
TACI were copies of its tax returns. He received none of the
books and records of TACI’s clients. Korrub, Transcr. at 1807-
1808.
In any event, the documents which were the subject of the
IRS summons enforcement proceeding did not include TACI’s tax
returns. The summons sought the books and records of one primary
“client”, namely, the Kanters, relating to transactions involving
the Kanters for 1983, 1985, 1986, 1987, and 1988. United States
v. Administration Co., 74 AFTR 2d 94-5256, 94-2 USTC par. 50,480
(N.D. Ill. 1994), affd. 46 F.3d 670 (7th Cir. 1995). These
records were not given to Korrub; instead, Gallenberger gave them
to Kanter. Gallenberger, Transcr. at 1969-1973.
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