-221-
to Kanter. Gallenberger, Transcr. at 2510, 2713. After
respondent requested production of the THC records, Kanter never
asked Gallenberger for them. Gallenberger, Transcr. at 2517.
Kanter possessed THC’s records but failed to produce them.
Kanter also possessed the books and records of IRA, TMT,
Carlco, and BWK. When respondent requested production of the
records of IRA, TMT, Carlco, and BWK, they had to be retrieved
from Kanter. Gallenberger, Transcr. at 2714-2715.
Gallenberger and Kanter possessed records relevant to
determining the ownership of IRA and THC. At the summons
enforcement hearing, Gallenberger testified that she had the
information available to decide, herself, the ownership of any of
PSAC’s clients. United States v. Administration Co., 74 AFTR 2d
94-5256, 94-2 USTC par. 50,480 (N.D. Ill. 1994); Exh. 9047--Mem.
Op. and Ord. dated June 22, 1994, at 6.
Neither Gallenberger nor Kanter produced stock ledgers for
IRA, THC, Carlco, TMT, or BWK. With respect to Carlco, TMT, and
BWK, the only documents Kanter produced concerning ownership were
copies of initial stock certificates showing that the Kanter,
Ballard, and Lisle family trusts owned the preferred stock of
BWK, TMT, and Carlco, respectively, and a copy of an initial
stock certificate showing that IRA owned the common stock of
these entities. No documentary evidence was introduced to show
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