-276- conduit to transfer to Lisle at least a portion of his share of payments remitted to THC.117 b. THC Transfers to Kanter During the period 1983 to 1984, THC transferred substantial sums of money into TACI accounts, and TACI transferred smaller amounts back to THC. During this same period, Kanter received substantial loans from TACI, and many of these loans, totaling approximately $1.3 million, had not been repaid when TACI filed for bankruptcy in early 1988. There is no evidence that Kanter ever paid any principal or interest on these loans.118 Kanter arranged for transfers from THC to TACI and from TACI to himself with no intention of repaying TACI or THC. F. Kanter-Related Entities Were Shams 1. IRA and THC IRA, THC, and their subsidiaries served no legitimate business purpose with regard to the transactions at issue in these cases. The entities did not have employees and generally only used the services of bookkeepers and administrators to record transactions, receive and disburse funds, and handle 117 As previously noted, an earlier ruling in these cases bars an additional allocation of income from the Travelers transactions to Lisle. Because we are convinced that Lisle received at least $682,250 from the Travelers transactions, we shall take this factor into account and reduce the allocation to Kanter by a like amount. 118 Gallenberger believed the TACI bank records that would have clarified many of the questions surrounding Kanter’s loans were last in Kanter’s possession.Page: Previous 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 Next
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