-272- e. Additional Loans to Lisle’s Grantor Trust Between 1988 and 1990, IRA and Kanter made additional loans to Lisle’s RWL Cinema Trust. These additional loans suggest that either the earlier loans to RWL Cinema Trust were not worthless when IRA wrote them off or the transfers were never valid loans in the first place. f. Consulting Payments to Ballard’s and Lisle’s Adult Children From 1984 to 1989, IRA made loans to KWJ Partnership totaling $249,000. KWJ Partnership was formed by Carlco (45 percent), TMT (45 percent), and BWK (10 percent), which were managed by Lisle, Ballard, and Kanter, respectively. As of July 30, 1990 (the date KWJ Partnership filed its tax return for 1989), these loans had not been repaid. During much of the period 1982 to 1989, KWJ Corp. and KWJ Partnership paid $1,000 per month to Ballard’s and Lisle’s adult children and deducted the payments (which totaled $313,000) as consulting fees. As the managers of Carlco and TMT, Lisle and Ballard were aware of and acquiesced in these payments. Although it appears that some of the children contacted Kanter at various times with recommendations and suggestions for investments, the record reflects that for many of the years in question they did little or nothing to earn the payments. In fact, in letters to the children terminating the payments in February 1990, Kanter stated that “no services appear to have been performed for aPage: Previous 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 Next
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