-219-
Court’s order. See United States v. Administrative Enters., 46
F.3d 670 (7th Cir. 1995).
D. Requests for Production of Documents
PSAC maintained records for Kanter, a number of his family
trusts, and IRA and THC. Before trial, there were “agreements
* * * [between respondent and petitioners] that certain third
party production [records of THC] would be made”. Shortly before
the close of discovery, the agreement fell apart. United States
v. Administration Co., 74 AFTR 2d 94-5252, at 94-5255, 94-2 USTC
par. 50,479, at 85,770. Kanter first promised to produce THC’s
books and records in the possession of PSAC and then, in early
February 1994, notified respondent that the THC records were
records of third parties over whom Kanter had no control. Id.
Kanter’s position was that THC was a third party and discovery on
Kanter was not discovery on THC. Dick, Transcr. at 2509. In the
summons enforcement proceedings, the District Court found that
this “eleventh-hour” change of position by the Kanters was
indicative of bad faith on the part of the Kanters. United
States v. Administration Co., 74 AFTR 2d 94-5252, at 94-5254, 94-
2 USTC par. 50,479, at 85,769.
At the start of the trial in these cases, respondent issued
subpoenas to various Kanter-related entities requesting
production of documents. Exh. 9045. In addition to the books
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