-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 a
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