Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 199

                                                -271-                                                   
                  c.  Sale of Grantor Trust Notes for $1                                                
                  In December 1987, IRA held a receivable of $507,648 due from                          
            IFI.  IRA transferred the receivable back to IFI in exchange for                            
            all of IFI’s assets, which included receivables due from                                    
            Ballard’s and Lisle’s grantor trusts as well as receivables due                             
            from Ballard ($196,648) and Lisle ($28,284), respectively.  IRA                             
            then sold certain of the receivables due from Ballard’s and                                 
            Lisle’s grantor trusts (with a face value of approximately                                  
            $384,000) for $1 each to MAF, Inc.  Morrison, MAF’s president,                              
            admitted that MAF engaged in the transactions merely as an                                  
            accommodation to Kanter.  In addition, after writing down the                               
            value of the receivables due from Ballard and Lisle to $84,889                              
            and $12,185, respectively, IRA treated these receivables as bad                             
            debts for which it claimed deductions on its 1987 tax return.                               
                  After the IRS began its examination, Kanter contacted                                 
            Ballard and Lisle to discuss repayment of their debts.  These                               
            discussions were merely postexamination window dressing.                                    
                  d.  IRA Loans to Kanter                                                               
            At the end of 1989, IRA’s records reflected loans to Kanter                                 
            totaling $600,000.  There is no evidence that any principal or                              
            interest was paid on these loans.                                                           











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