Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 194

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            Lisle used Essex Partnership as a conduit to receive a portion of                           
            the management fees paid to GHM on the Gateway Hilton and Midland                           
            Hilton management contracts (through distributions to IRA), and                             
            Kanter received a separate portion of those same management fees                            
            (through distributions to THC).  As discussed in the flow-of-                               
            funds analysis below, the distributions that IRA received from                              
            Essex Partnership were distributed to Carlco, TMT, and BWK.                                 
            Essex Partnership represented an effort by Kanter, Ballard, and                             
            Lisle to assign to IRA and/or THC income that they earned.                                  
                  E.  Flow-of-Funds Analysis                                                            
                  The Court’s additional findings of fact regarding the flow                            
            of funds from The Five to IRA and from IRA ultimately to Kanter,                            
            Ballard, and Lisle are summarized in table 11.  Table 11 shows                              
            that with so-called capital contributions, loans that were never                            
            repaid, and other payments to Kanter, Ballard, Lisle, and their                             
            families, IRA transferred to Carlco and/or Lisle, TMT and/or                                
            Ballard, and BWK and/or Kanter, in a roughly 45/45/10 percent                               
            split, all of the payments from The Five (and nothing more).  The                           
            flow-of-funds analysis also demonstrates that Kanter, Ballard,                              
            and Lisle had unrestricted use and enjoyment of the assets IRA                              
            transferred to BWK, TMT, and Carlco, and they treated those                                 
            assets as their own.                                                                        
                  The Court’s additional findings of fact regarding the flow                            
            of funds from The Five to THC, and ultimately to Kanter and                                 






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