-268-
Lisle, are set forth supra pp. 207-213. Although the funds paid
by The Five to THC could not be traced directly to Kanter and
Lisle because of a lack of complete general ledgers for THC and
TACI for the years in question, we are satisfied that the
transfers of funds between THC, TACI, and Kanter documented in
the record demonstrate that Kanter used the funds from THC as his
own. We likewise conclude that Kanter arranged FPC Subventure
Partnership as a conduit to pass to Lisle at least a portion of
Lisle’s share of the fees that Schaffel paid to THC.
The following summary (subsections 1-4) highlights the more
important aspects of the flow of funds.
1. Payments to IRA: 1977 Through 1983
During the period 1977 through 1983, IRA (and Zeus) received
in the aggregate approximately $5 million in payments from The
Five. Although IRA reported these payments as income on its tax
returns, IRA paid very little in taxes.
In 1984, IRA began distributing some of its cash and
partnership interests to Carlco, TMT, and BWK in a 45/45/10
percent split. Specifically, during 1984, IRA transferred
approximately $4.2 million to Carlco, TMT, and BWK. The
distributions to Carlco and TMT represented a large portion of
Lisle’s and Ballard’s shares of the payments that IRA received
from The Five.
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