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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.
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