-240-
to influence Prudential and Travelers to award business to The
Five, and to varying degrees they were directly involved in the
decisions that led to Prudential’s and Travelers’ business
dealings with The Five. Those factors, in combination with the
flow of funds–-the fairly precise division of the proceeds of the
scheme among the three--remove all doubt in these cases in
respondent’s favor. We conclude that all the circumstances, when
gathered together and viewed as a whole, constitute compelling
and unmistakable evidence that Kanter, Ballard, and Lisle earned
the income in question and Kanter’s and Ballard’s conduct in
these matters was fraudulent.112
Kanter, an experienced and knowledgeable tax attorney,
established a complex web of corporations, partnerships, and
trusts as part of a plan to receive, disguise, launder, and
distribute payments from The Five to himself, Ballard, and Lisle.
The complex laundering mechanism of sham corporations and other
entities that Kanter put together included among others IRA, THC,
Carlco, TMT, BWK, KWJ Partnership, Essex Partnership, Zeus, IFI,
HELO, TACI, and PSAC.
Ballard and Lisle were sophisticated and experienced
businessmen who held two of the highest ranking executive
positions within the real estate division at Prudential’s
112 The Court of Appeals for the Fifth Circuit has already
ruled that Lisle is not liable for additions to tax for fraud.
Estate of Lisle v. Commissioner, 341 F.3d 364 (5th Cir. 2003).
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